Disclosure Log

Document: DOCUMENT-45

For Official Use Only

Pricing Reference Group, Item: Item_3._2

Matter for Decision - Review of Pricing Arrangements for Supported Independent Living Prepared By David Cullen Chief Economist

Purpose:

To seek endorsement from PRG regarding recommendations outlined in Attachment A.

Recommendations (PRG recommends through CEO):

No changes are recommended due to identical efficient costs between current pricing arrangements under SIL vs non-SIL settings;
Operational Guideline review needed; clearer advice should be given about high intensity supports/sleepover/active overnight inclusion criteria, circumstance reviews when vacancies impact cost delivery, timeframes agreed upon during plan revisions ensuring certainty on revenue if plans aren’t completed timely, including providers’ ability claim support worker ratios until a plan is reviewed appropriately.

Background & Supports within NDIS:

Supported Independent Living involves daily task assistance and skill-building, not including rent or board/lodging.

DISCLOSURE LOG

FOR OFFICIAL USE ONLY Pricing Reference Group | Item 3.2 | Date: April 15th , Year : 2020

MR25/01967 FOI 24/25-2242

FOR OFFICIAL USE ONLY

Pricing Reference Group	15 April 2020	Item 3.2

4.2 The Review found that there was evidence to suggest that, compared to activities of daily living services delivered in a non-SIL setting by an efficient provider, an efficient SIL provider faces:

(a) higher rates of permanent employment (85.1% compared to 70.0%);

(b) higher workers compensation premiums (2.4% compared to 1.7%);

(d) higher base wages for supervisors (11.9% higher on average); and

(e) higher annual leave costs associated with great leave entitlement (5 weeks per year compared to 4 weeks per year).

4.3 Some of these effects add to the cost of service provision whereas others reduce that cost. The net effect, as Exhibit 30 (taken from the draft report) shows is that the fully loaded costs of efficient service provision in SIL and non-SIL settings are essentially identical. That is, $55.47 for efficient assistance with daily living providers compared to $55.76 for efficient SIL providers.

4.4 As such, the Review does not recommend any changes in the current SIL pricing arrangements.

Exhibit 30: Efficient Costs in SIL and Non-SIL Settings

[Bar chart graphic displaying cost breakdown for ADL Efficient vs SIL Efficient]

5. Discussion – Recommendation 2.2

5.1 The Review acknowledges that providers and planners do not always agree on whether the cost of a SIL roster of care should be calculated using the standard or high intensity price limits or whether the cost of a SIL roster of care should include active overnight or a sleepover.

5.2 While these affect the value of the SIL plan, they are not a pricing issue, and the Review considers that this is a matter best addressed through the Operational Guideline for SIL.

Review of Pricing Arrangements for Supported Independent Living Page 428 of 1049 3.2.3

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FOR OFFICIAL USE ONLY

Pricing Reference Group | Date: April 15th , Year : 2020 | Item Number: item-3-dot-2

Further,

The review also recognizes that providers must continue supporting an existing resident participant during any period when their plans undergo reviews and there’s thus risk they might provide different support ratios than those approved.

The review acknowledges vacancies present issues but not necessarily deficiencies within unit price limits; instead it points out planning arrangement inadequacies which don’t always adjust participant plans based on vacancy changes;

####### If these were uniformly distributed across sectors then adjusting prices would have been possible yet available data shows otherwise so addressing such risks should be through plan reviews rather pricing adjustments directly. ######## Review suggests strong arguments exist where this risk could be jointly managed between provider & NDIA, implying if NDIA doesn’t complete its planned review timely enough, a provider is entitled to compensation covering services delivered until completion occurs. ############ Therefore,the review recommends reviewing Operational Guidelines for SIL: a) clearer advice regarding high intensity supports/sleepover/active overnight inclusion in SIL plans; b) change of circumstance reviews whenever vacances significantly impact costs associated with delivering supports at SIL settings ;and c) agreed timeframes ensuring certainty about revenue from completed or addressed billing matters once the plan review isn’t finished as expected.

Next Steps

6.1 Draft report will go before CEO for presentation towards NDAI Board meeting scheduled May25th , Year: ‘2021’.

Price Regulation Unit tasked working alongside other Agency areas implementing recommendations including guidance participants/providers/partners and staff alike.

Recommendations are set forth July first year:‘2021’, published four weeks prior implementation date.

Risks

7.1 Due existing Scheme sustainability concerns sector might view current Pricing Arrangements Review as cost-cutting exercise; these can be mitigated via ongoing communications during which it’s noted that this review forms part larger program aimed improving shared living arrangements support.

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For Official Use Only

Pricing Reference Group | Item 3.2

| — | | Date: April 15th , year 2020| 7. The broader improvements in SIL aim at enhancing participant choice & control; simplifying NDIA processes ; addressing pressures on Scheme sustainability . These enhancements shall be implemented through multiple steps involving consultation sessions with participants, service providers along other stakeholders during consideration.

Disclosure Log

Document: NDIS Review Report - April 2021

Title:

National Disability Insurance Scheme: Review of Pricing Arrangements for Supported Independent Living Report April 2021

Disclosure Log

Copyright

Copyright in the information contained in this document is owned and protected by the National Disability Insurance Scheme Launch Transition Agency (National Disability Insurance Agency).

Use of National Disability Insurance Agency copyright material

The material in this report, with the exception of logos, trademarks, third party material and other content as specified, is licensed under Creative Commons CC NC licence version 3.0. With the exception of logos, trademarks, third party material and other content as specified, you may reproduce the material in this document provided you acknowledge the National Disability Insurance Agency as the owner of all intellectual property rights in the reproduced material using ’© National Disability Insurance Scheme Launch Transition Agency’and do not use it commercially. Reproduction any creative commons material within a document subject to conditions available on site for this material.

Terms that we use

Acronym	Description
DSW	Disability Support Worker
EBA	Enterprise Bargaining Agreement
FLS	Front Line Supervisor
ILO	Individualised Living Options
NDIA	National Disability Insurance Agency
NDIS	National Disability Insurance Scheme
SCHADS Award	Social Community Home Care & Dis Services Awar210
SIL	Supported Independent Living

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Introduction…7

Context……7

Conduct of the Review…..11

Methodology…….12

Findings…………16

Wages and On-costs………16

Workforce mix……….22

Utilisation……………25

Supervision costs……..30

Overheads…………….40

Supply Costs Specific To SIL Services..35

Conclusions………..40

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List of Exhibits

Exhibit 1: Average Annualised Plan Budgets, 30 September 2020 … Page \ref{exhibit-avg-plan-budgets}
Exhibit 2: Average Annualised Payments, 2019–20… Page \ref{exhibit-avg-payments}
Exhibit 3: Schematic overview – NDIS Disability Support Worker Cost Model…Page\ref{schem-overview-cost-model}
Exhibit 4: Representativeness of the 2019–20 Financial Benchmarking Survey Data …Page\ref{representative-survey-data}
Exhibit 5: Breakdown of provider categories used in this analysis……….Page\ref{provider-breakdown-analysis}
Exhibit 6: Box Plot — Base Wages of Disability Support Workers…………..Page\ref{boxplot-base-wage-disability-support-workers}
Exhibit 7: Summary Statistics—Base Wages of Disability Support Workers………………………..Page\ref{summary-statistics-base-wage-disability-support-worker}
Exhibit 8: Regression Analysis—Base Wages of Disability Support Workers………….Page\ref{regression-analysis-base-wage-disability-support-workr}
Exhibit 9: Box Plot -Workers Compensation Premiums………………….Page\ref{boxplot-compensation-premiums}
Exhibit 10:SummaryStatistics-WorkersCompensationPremiums………………….Page\ref{summarystats-compensation-premises}
Exhibit 11RegressionAnalysis-Worker’sCompenationPremiums………………… Page \ref{regressionanalysiscompensationpremiums}
Exhibit 12BoxPlotPermanentEmploymentShare……..Page\ref{permanentemploymentshare-boxplot}
Exhibit 13SummaryStatistcs Permanent Employment Share ………Page\ref{permanentemploymentsummarystatistics}
Exhibit 14RegessionAnalysis Permant Employement Share … …..Page\ref{permantemploymentsregressionsanalyses}
Exhibit 15BoxPlot Staff Utilisation Rate . .. ……..Page\ref{staffutilizationrate-boxplots}
Exhibit 16 Summary Statistic sStaffUtilisationRate……………..P age\ref {summarystatistikssstaffutilisationrat e } *Exhibit 17 Regression Analysis – Staff Utilisation Rate …………… P a ge ef egres si on analys is - staff utili sat ion rate
Exhibit 18 Box Plot-Time spent training as share of non-billable hours. ……Pa ge\ref{boxplottime-spent-training-as-share-of-nonbillable-hours}
Exhib it 19 Summary StatisticsTime Sp ent Training As A Share Of Non-B ill able Hours… Page \ref{s ummarystatistics-time-spent-train ing-as-a-share-of-nonbillable-hou rs}.
Ex hibit20 Reg ression Anal ysis Time S pent Tr ainin gAsAShareOfNonBill ab leH ours…… Pa ge\ref{regr essionanalysistime-spenttrainingasshareofnonb i llab lehours}
E xhibits Base Wages Supervisors … …..Page\ref{basewage-supervis ors-exhibit} *E xhi bitSummaryStatistcsBaseW agesSupervisorS . ………Page\ ref{summarystatistics-base-wage s-supervisorsexhibit} *Exh ibitRegressionAnalysisB e sw ageSu p erviso r s…………P ag e\reff regressionanalysiss base wages supervisorsexhibit e *ExhibitBoxPlot Sup ervisi on Ratio ………….. P age ef {supervisionratio-boxplot }
ExhibitSumm ary Statistic ssuperv is ionRatio. .. ……Pa ge eff sum m aryst at ics - supe rv issio n ratio
Exhib it Regression Analysis – Su pervisi o ns Rati o…………… Page \ref{regression-analysis-super visions-ratio}
Expo b it Box Plot Overhead Costs …………… Pag e\ref{boxplotoverheads-costs}
Ex hibit Summar y StatisticsOver headCosts…… Pa g e\ref{s um marystatistics-overhe adcosts}.
Exp rib t Reg ressi ons Anal ys i s Ove rh edC ost s………Pag e\re f{ regressionanalysisoverhea d costs }.*E xhibitsEfficientCo stsin SILandNonSILSettings…..Page\ref{efficientco stssilnonsilsettings-exhibit}

Executive Summary

On July 01/2025, the National Disability Insurance Agency introduced new pricing arrangements for Supported Independent Living - support activities daily living in shared arrangement.

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Review of Pricing Arrangements for Supported Independent Living

remaining participants receiving supports in SIL (Supported Independent Living) for a period after vacancies occur. Allowing this flexibility helps providers recover rostered staff costs more quickly upon vacancy occurrence but would need careful management due to incentives reducing provider motivation filling vacant positions—restrict higher support ratios until later periods if needed. Billing remaining participants at increased rates during vacancies likely exhausts their funding sooner than expected so it may also make sense to conduct circumstances changes assessments on all affected participants’ arrangements ensuring coordinated funding amounts maintain continuity among shared supports within each arrangement. The Review acknowledges that providers must continue supporting existing residents throughout planning reviews which could lead them providing different ratio services compared those approved as part thereof; thus strong arguments exist regarding risk sharing between NDIA and Providers, implying payment should be made when plans aren’t completed timely. It recommends reviewing Operational Guidelines related to SIL:

Clearer advice about high-intensity/sleepover/active overnight inclusion criteria;
Change-of-circumstance review mechanisms impacting cost delivery under significant vacancies, avoid delays or billing issues not addressed promptly.

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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. Within NDIS Supported Independent Living SIL is one type help supervision daily tasks build their skills. It intended participants who require support live in shared living arrangements other contemporary models exist participant include assistive technology home modifications or Individualised Living Options ILOs July NDIA introduced new pricing arrangement quotation process whereby agency provider negotiated individual price each SIL participant replaced fairer transparent process where Agency determined reasonable necessary supports each participant relevant legislation Under these arrangements maximum price that Agency willing pay component hourly supports of SIL were determined by NDIS Disability Support Worker Cost Model line all other supports activities daily living The purpose current Review suggest improvements way which NDIA estimates fully loaded cost delivering hour SIL supports a shared living arrangement included identifying whether different costs arise delivery activities daily living supports sharing setting quantifying any differences given difference structures delivering supports compared to other settings

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Review of Pricing Arrangements for Supported Independent Living

There were 412,5**43 active participantswith an approved plan in the Scheme at September, September. Of these,**23****457(*5.%of all participants)had SIL includedin their plans. A total $29 ext{ billion} annualised committed supportwas participantplansasat September, **$8 ext{billioncommittedparticipantplanforSILparticipants(**28% ext{allcommitments}). The yearto September *,the average plan budget for participants in arrangements was compared to , with largest found in participants living Northern Territory.The results each state and territory are provided Exhibit below:

Average Annualised Plan Budgets, September *

State/Territory	Participants in SIL	Participants not in SIL	All participants
New South Wales	35000	£60000	£71£00
Victoria	325000	$£54,£0000	$£64,£000
Queensland	364*000	£60000	£77,**000`
Western Australia	3**14,`000	`£58**,000	`£74`,000`
South Australia	$347,*000	`$£50,,000	$68,,,000*
Tasmania	$376,,,,000	`$£53,,,,,,,,000	``£83$,000`
ACT	$367,000	``$£46.,000	```£63.000`
Northern Territory	$593,.000	```$£86.`000	``£137`.000`

For financial year 2019- the average payment for participants in arrangements was compared to , with largest payments being made from participants living NorthernTerritory.The results each state and territory are provided Exhibit below.
Note these reported values included all supports plan not just specific SIL.*

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Review of Pricing Arrangements for Supported Independent Living

Exhibit 2: Average Annualised Payments, 2019–20

State/Territory	Participants in SIL	Participants not in SIL	All participants
New South Wales	$321{,}000	$35{,}000	$55{,}000
Victoria	$302{,}000	$33{,}000	$46{,}000
Queensland	$322{,}000	$40{,}000	$58{,}000
Western Australia	$228{,}000	$32{,}000	$43{,}000
South Australia	$324{,}000	$29{,}000	$49{,}000
Tasmania	$339{,}000	$32{,}000	$64{,}000
ACT	$326{,}000	$31{,}000	$48{,}000
Northern Territory	$535{,}000	$45{,}000	$99{,}000
National	$315{,}000	$35{,}000	$52{,}000

NDIS Pricing Arrangements and the Disability Support Worker Cost Model

One of the principal objectives of the NDIS is for people with disability to exercise choice and control over how, and with which providers they spend their available budgets. The role of pricing in the NDIS therefore very important. Pricing can also affect: promoting innovation; improving service quality outcomes; as markets develop more effectively it expected that NDIA as market steward will be less interventional, currently ndia varies its approach regulation prices between:

No Regulation (deregulated): this typically used cases where highly competitive transport.
Imposition price limits these represent maximum allowable payables participants types supports This approach significant number developing growing such assistance daily living activities. Quotable Supports participant obtain quotations suppliers provide part verifying fair reasonable further information on ndias approach found ndis strategy Annual Price Review 2020–21. The NDIS Disability Support Worker DSW)CostModel one methodology ndia uses inform decisions delivered by Disability Workers imposes price limit Exhibit provides schematic overview NDIS Disability Support Worker(DSW )cost model.

6 https://www.ndis.gov.au/media/1820/download 7 https://www.ndis.gov.au/media/2413/download 8 https://www.ndis.gov.au/providers/price-guides-and-pricingredacted

9 Page redactedof {,}1{} of { }

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Exhibit 3: Schematic overview – NDIS Disability Support Worker Cost Model

Base pay Four DSW levels (\text{2}.4/\text{3}.0), \mathbf{5}, and so forth based on SCHADS classification.
Shift loadings As per the SCHADS Award applies a loading for permanent staff working weekends public holidays afternoons nights apply casual loading weekdays weekend public holiday afternoon night.
Leave allowance As per the SCHADS award includes annual leave personal leave public holiday long service leave NES).
On-costs Superannuation (9% workers compensation employee allowances (1%).
Supervision costs Base pay + leave cost + oncost supervisors with three levels supervisor pay DSW level 3, etc., as with frontline staff based on SCHADS and NES Supervisor to ratio is one fifteen.
Permanent workforce Assumes of work force seventy percent.
Utilisation Incorporating breaks training other varies across staff levels ninety two percentage point eight zero for DSW Level four.)
Overheads Assumed twelve percent direct cost overheads.
Margins Assume two applied directly plus overheads.
FWC Inputs Each year Fair Work Commission determines increases wage rates current iteration also includes last stage Equal Remuneration Order. |

Conduct of the Review

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

Issues Papers and Submissions

An Issues Paper was released on 31 August 2020 together with a public call for submissions. The closing date for submissions was initially 13 September 2020, later formally extended to 25 October 2020. Some 84 submissions were received by the closing date. A total of 92 submissions had been received and analysed by 31 December 2020.Most submissions (81) were from service providers, with one received from a builder of Specialist Disability Accommodation.A further four submissions were received from provider peak bodies.One submission was received from a workers union.The participant voice was also heard,with three submissions from participant advocacy bodiesand twofrom participants or their family/nominees.Providers who made submissions rangedin size from servicing just onesingleparticipant insil arrangementsto over 500participantsinsilarrangements.withthe averagebeing 82SILparticipantsand themedianof SILparticipants.Theyalsorangedfromhavingunder$50,000INDISrevenue toover $100 million ,witheaverage being around $16 .l5million anda medianbeingaround $7.l9milion.

Consultations With Peak Bodies

In addition toreleasing Issues Paper,the Review held virtual consultations wit sector stakeholders across Australia.This included meetings wi Provider an Participantpeakbodiesas listed below.On 26 August 2020.theReview met wth members o following participantpeak groups:Australian Federation OfDisability Organisations; Disabilty Advocacy NetworkAustralia: InclusionAustria ;an JFA Purple Orange. On 28 July 2020 the Reviwmetwi memberso ffollowingprovider peagroupsAbility FirstAlliance and National Disability Services.Working GroupsFour workinggroups were alsoset up.involving39representativesfro msector todiscusstheirconcerns.Theseworkinggroupsmeta total of three times each,two time before thereleaseoffIssuesPaperandafteritclosed.- Smaller Providers - organisations (August,August December)- LargerProviders-organisatons(August,AugustDecember)Very Large Providers - organizations(October,August,D ecember);and-Rural/Remote Providers - organisation s(August, August Decem ber).

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Consultations with Other Schemes

A virtual meeting was held on August 13th, 2020, to compare pricing methodologies among various schemes. The following organizations participated in a comparative study:

Department of Veterans Affairs;
icare New South Wales;
Lifetime Support Authority of South Australia ;
SeaCare;
State Insurance Regulatory Authority NSW;
Victorian Transport Accident Commission;
WorkCover Queensland;and Worksafe Victoria .

Desktop Research

The review conducted research comparing employment conditions within Social , Community Home Care Disability Sector Industry Award 2010 some publicly available enterprise bargaining agreements offering SIL supports It compared price limits activities daily living similar supported independent living input cost drivers other schemes sectors.

Methodology The analyses seeks understand degree key cost parameters differ between delivery of SIL and community services nature analysis means it not possible fully isolate costs supplying from supply activities daily living As such each parameter interest addressed questions: Do cost differences providers that do provide SIL? Is concentration associated changing cost?

First question baseline service characteristics offers some SIL those don’t offer any. Second question relationship service cost delivered by providers.The Review had access two types data sources Financial Benchmarking Survey large number ( n=9 ) Alliance20 ( n =) Ability First ( n=13 ). Qualitative submissions consultations employed to triangulate against this quantitative document

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The 2019–20 Financial Benchmarking Survey Data

Deloitte Access Economics were engaged by the NDIA to conduct a financial benchmarking survey of providers for FY2019-20, with a particular emphasis on the parameters that lie within and underlie the NDIS Disability Support Worker Cost Model. This dataset captures data from an sample size of approximately eight hundred forty-eight providers.The representativeness of these data are displayed in Exhibit4 Overall,the dataset represents sector well.Whilethe survey dataset slightly underrepresents providers primarily offering SIL care (majority-SIL Providers), analysis confirms characteristics captured majority-SIL provider’s alignment with population.

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Differences between SIL and non-SIL providers in the survey

The unique financial benchmarking survey dataset represents the best available evidence for undertaking the analysis.^{\text{footnote}}. The key limitation of this dataset is that the benchmarking survey did not seek to differentiate between costs for community activities of daily living services and SIL services. As most providers supply a mix of services including community activities of daily living, SIL, and other services such as capacity building the analysis has divided providers into two categories four subcategories presented Exhibit \ref{exhibit:5}:

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Statistical Analysis of 2019-20 Financial Benchmarking Survey

The analysis used the following statistical techniques to identify relationships between the variables:

Confidence intervals for percentiles were estimated throughout the analysis to understand the range within which the population value of the percentile is likely to fall. Further, confidence intervals authorize a comparison across groups in sample with equivalence of values at different percentiles compared against broader populations’ statistics.
Linear Regression allows assessment whether a specific variable has statistically significant linear relationship conditional mean on costs; meaning change an explanatory variable associated changes other held constant. Linear Regressions are applied report-wide understanding cost parameter’s means and their related factors.
Quantile Regression assesses if there exists any statistically relevant association among quantiles (or points) along distribution curve regarding cost parameters, isolating these associations specifically focusing upon median (middle), lower quartile (bottom quarter), upper quartile (top three-quarters). Quantile regressions analyzed extensively this document explores connections between various influencing elements concerning ‘efficient cost parameter’.
- Utilizes bootstrap standard errors as part process.
- Reports pseudo R² metrics during regression analyses.

Findings

The purpose of the Review was to suggest improvements to the structure of the NDIS Disability Support Worker Cost Model to estimate the fully loaded cost of delivering an hour of SIL supports in a shared living arrangement.

Identify whether there were different costs that arise in the delivery of activities of daily living supports in a shared living arrangement that do not arise in other settings; and quantify any differences that may be required in the key parameters of the NDIS Disability Support Worker Cost Model, given the different cost structures of delivering supports in shared living arrangements compared to other settings.

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Base hourly wages

Some submissions argued that staff in SIL were paid higher wage because participants tended have more complexity and therefore needed highly qualified workers. However analysis Financial Benchmarking Survey data does support contention base salaries are lower non-SIL settings.

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Review of Pricing Arrangements for Supported Independent Living

Regression analysis (Exhibit 8) confirms that there is no clear relationship between the extent to which a provider is engaged in the provision of SIL and the average base wage that the provider pays to their disability support worker employees.

The coefficients for the SIL indicator variable and SIL share variable are both not statistically significantly different from zero. The regression variables exhibit some evidence that average base wages are slightly lower for larger organisations: | Regression Variables | Mean | Median | 5th percentile | 75th percentile | |- |- |- |-| | SIL Provider Indicator | -032 | .31 |.03 | -46 | Percentage Revenue Sourced From SIL | .93 | .74 | .88 | .02 | Number Of Clients (log) | .83** | .60 | .85** | .70 | Number Staff (log) | -1,84** | -2,04**,|-1,23,|-2.32 | Staff-Supervisor Ratio(log ) | .14 |,39|.83* **` | -.38 R²: 4%, ,% ; 3.%; %; Note:*and * indicate significant at thresholds respectively ( observations).

On-costs

The principal on costs recognised in NDIS DSW Cost Model include Superannuation Workers Compensation and Employee Allowances The Review found no evidence the cost of either superannuation or employee allowances varied between SIL nonSIL providers. The consensus among providers that workers compensation was higher in a SIL environment In part they argued this is driven because SIL Providers are sometimes classified into different risk pool than nonSIL provider For example New South Wales SIL Provider are sometimes classified Residential Care Services not elsewhere classed sector whereas most activities daily living supports are classified as NonResidential Care Services not else where classed sectors Basic NSW Worker Comp Industry Classification Rates prior to adjustments for size experience these two sectors 2021 are %; %%respectively.`

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Review of Pricing Arrangements for Supported Independent Living

Analysis of the Financial Benchmarking Survey data confirms that SIL providers tend to have a higher rate of workers compensation premium as a percentage of wages and salaries compared non-SIL providers (Exhibit [and Exhibit] #ref-10). The data indicates average provider offers SILL services pays worker’s compensation premiums at an annualized basis of $3 ext{m}$. Compared with median provider offering no such service. However level increases in line share provision. In particular those who make up more than their business have an average workers’ compensation premium of . A similar relationship is seen efficient, which has a percentile of non-SIL providers having work comp prem of % compared to percentiles all SLL providers and for efficient providers making up more than their business.

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workers compensation premiums paid by a provider. This indicates that there isn’t significantly different across regression equations; however, a statistically significant relationship between share revenue and workers’ compensation premium increases. an increase in proportion received from SIL services leads average organization’s worker compensation premium increasing .009 percentage points per each point increased. e.g., an organisation with zero revenue sourced would have had its worker compensation premium at % one otherwise identical having all their revenues coming through SIL should be expected as %. A similar effect observed efficient (25th percentile) providers so given non-SIL providers are then the expected average is “.” # Exhibit Regression Analysis – Workers’ Compensation Premiums¹² |Regression variables | Mean | Median | |-:|–:-|–:| sil indicator | -3e-4 | -.0 pct rev source sil | 1.e+−³ ^*| 1._e+⁰ | .7._e+−³ | **.7._e+−³ | nbr clients log | -.86^- | −.86^- | −.86^- | −.86^- ||staff supervisor ratio headcount log | — | – | –– | ——||average base wage front line superv | .9^. | .9^. | .9^. | .9^. ||average base wage dsw | .9^.• | .9^.• | .9^.• | .9^.• ||qld provider indicator | .25^-∗ | ∗.25^-∗ | -.0^-∗ nsw provider indicator | 3e-4* ^*| 1._e+⁰ | .7._e+−³ | **.7._e+−³ | vic provider indicator | -.86^- | −.86^- | −.86^- | −.86^- ||sa provider indicator | -3.e+.^. | — nbr clients log | staff supervisor ratio headcount log | average base wage front line superv | average base wage dsw | qld provider indicator |Mean Median R²| |.002,−.001,.00%||%.00%,,,****% pct rev source sil | Mean:Median:.009,.011**:R^2:%10.%||%.007.*,..017:, nbr clients log | mean median r² | .004,−.004**,-13.|-.005,-10.,%-7.-|-13. supervisor ratio (headcount) (log)|staff-supervisor ratio(headcount)(log)||average base wage(front-line supervisor) average base wage(dsw)||(qld provider indicator)|(NSW provider indicator) overtime costs Generally overtime were reported by providers as being higher in SIL than non-SIL services This was mostly attributed to the support needs of participants ¹² The equation regresses workers compensation premium paid against:

the SILL PROVIDER INDICATOR VARIABLE (if the provider delivers SLL otherwise); The percentage revenue sourced from SILL; Log number supported DSWs employed by the provider; and State Dummy Variables (1 if largest share derived).

Page 450/1049

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Providers argued that when a staff member could not fulfill a shift, the provider did not have the option to let the participant go without support. Workers often continued beyond shifts due to wrap-around nature; overtime varied but common at up-to-ten hours per week or house weekly among some providers; houses with complex participants likely needed more overtime as staff couldn’t leave unattended until comforted, some preferred minimizing rostering where possible because excessive overtime negatively impacted care quality from fatigue. The review acknowledges arguments about greater overtime prevalence specifically within SIL settings compared to other contexts yet lacks empirical basis estimating materiality difference recommending future benchmark surveys examine use efficiently.

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Review of Pricing Arrangements for Supported Independent Living

Workforce Mix

The DSW Cost Model recognises that the costs of employing casual and permanent workers differ. Therefore, The key questions outlined include:

Is there material difference between employees providing SIL vs non-SIL?
- If so: What aspects suited more or fewer? How large is this diff.? Average weekly hrs per week employed casually?
- Material difference avg weeks part-time employment?
Are temp replacement staff engaged differently often than full time?
- Key drivers & how much different cost?
Level worker standard/requirement?

Casual / Permanent Staff Mix

Many submissions argued higher prop永久workers in general. Casualization lower reported due preference skilled/experienced permanence req’d daily service support. Analysis confirms larger proportion permanently employed among providers with SIL services.

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providers (the 75^th percentile) SIL providers employ 77.5%of their workforceonapermanentbasis, comparedto70*.0*for non-SILproviders.

Permanent employment share box plot note:Data labels forthecentileare shown to highlight theefficient frontier within each category

| Respondent type | Sample size | Mean | Median | _{^{25^th}percentile}| _{^{75^th}percentile} |-|-|-|-|-| | All respondents |837 |44 extperiodcentered .3 % |{40} extpercnt{}.{2} | {12}.{ extpercnt}{ }{| extbf{{}}{ } extbf{{{ }}{72}.{6}%}| | on-SILrespondents |redacted | redacted | redacted {| redacted ||||Mixed(SIL/ADL)respondests |920 |54. { extpercent}{ }.% | 59 {.3}^{}% | 30.%. | **77..%****| * c-25% SILE respondenst |81 |48. extpercent{}.% | 46 extpercent{} extperiodcentered .6 {%} && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && && &&am

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Although there may some additional administrative costs involved in a workforce with a larger share of part-time workers, the Review did not find any evidence of significant differences in costs in this regard between SIL and non-SIL providers.

Agency Staff / Temporary Replacement Staff

It was fairly common for providers to report in response to the Issue Paper that they did not use Agency or temporary staff at all. Organisations that did report employing these types ofstaff said that they are more likely to do so for SIL than non-SIL services. All respondents who used Agency or temporary staff said that they were more expensive and that this sometimes de-incentivised providers from using them. Based on data from five providers, Alliance reported that agency staff hours accounted for about %ofallhours Ability First suggestedthattherewaspressuretokeephousesfullystaffedinSIL Theyarguedthathiscan necessitatetheuseoagencystaff overtime increased wagesandrecruitmentcosts One provider argued asAgencyStaffoftenhadtobeusedinsteadoffulltimeemployeesandthisshouldbeaccountedforinTheCostModel On balanced,theReviewdidnotconsiderthattherewassignificantevidenceofamaterial differenceinthecoststructuresofsilandsilosettingsintrespecttosiscostdriver LevelOfStaff ManyrespondentstotheIssuesPaperarguatedthaaveragelevelofworkerusedsils much higherthanallowedforthNDISDisabilitySupportWorkerCost ModelOneprovideruggestedthatinservicestheyemploystaffaround SCHADS level4They arguethatthiswasa becausemoreexperience wasneededtodalewithchallenges -andan timesvolatility experienced in the SILEnvironment Aspectsocare suchasmedication managementandaliveryofspecializedservicesaretasks thataretrainandexperience soproviderswantedexperiencedstafwho weremorelikely tobedeliver these services effectively These claims are not however supported by theevidenceonbasepayrates insil and non-SIsettingsdiscussedabove TheFinancialBenchmarkingSurveydata does nosupportthecontention thatbasesalariesarethigherinSI settings(seeExhibit6andeXhibit 7 above) IndeedtheargivesalarypaidbySIL providersislower thanthesalary paidbynon-SIProviders It shouldalsobenotedthat25percentiles for bases salariesaresamequivalentfor SIandnon-SI ProvidersThese findings areno consistent with a consistentlyhigheruse of morequalified staffinSIs.

Utilisation

The NDIS Disability Support Worker CostModelrecognesthatstaffneedtospend someworktimeundertakingshbillablework includingbreaksandtraining Theneedtherefore soughtevidence onwhether therewere materialdifferencesinthese arrangements between SILprovidersandon-SIProviors. The key questions fore Review as outlined InIssuesPaper,ar:

Do training requirements - an associated costs workers differ betweenservicesandsiloservicess If ther is adifference whatare thekey driversofthis difference Howlargeisthisdifference?

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Is there a material difference in the non-direct care activities that staff in SIL services compared to staff in non-SIL services are required to undertake? What are key drivers and how large these differences?

Utilisation: Billable vs Unbillable Hours Most respondents mentioned workers spent most time delivering supports with responses between 80-95%. Providers noted variation among participants.

Respondents suggested SIL staff were more engaged unbillably due emphasis quality/safeguarding; includes team meetings/handover/increased reporting/coordination stakeholders household management. External stakeholder involvement/family meetings communication back-and-forth attributed indirectly participant Ability First reported family/stakeholder engagement accounts disability support worker hours standard participants high intensity participants In addition, they liaised coordinated other supports/services accounted same percentages efficient providers (the median provider achieved utilisation rate than no SIL service For efficient providers (25^th percentile) SIL providers achieved utilisation rates compared to non-SIL providers Exhibit Box Plot - Staff Utilization Rate


SIL provision `75%-100%` <div style=

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Exhibit 16: Summary Statistics – Staff Utilisation Rate

| Respondent type | Sample size | Mean (%) | Median % | `75th` percentile% | |-|-|-|-| | All respondents | 698 | 79.4 | 80 | 70. - 90. | | Non-SIL respondents | 495 | 77.9 | 80 | 70.- 88. | | Mixed (SIL/ADL) respondents | 203 | 82.7 | 84 |- * incomplete data*

Deeper regression analysis seems to show, however that utilisation rates do not differ significantly between SIL and non-SIL providers for median providers as the regression coefficient of relevant variables are statistically significant from zero. The observed differences in correlations with other factors These findings align survey results AbleInsight 197-18 which showed average provider had comparable utilisation rate (95%) compared to average non-SIL provider(93%).

Exhibit Regression Analysis – Staff Utilisation Rate^**

| Regressor | Mean (%) | Median % | |-|-| | `SIL` indicator variable | 0.04 - 0.26* |- * incomplete data*

The equation regresses the percentage of labour time that is spent by DSWs employed on billable work against:

The SIL provider indicator variable (1 if SIL 0 otherwise);
Percentage revenue sourced from;
Square log number participants supported;
Log FLSs employed; and, average base wage paid to DSWs.

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A simple T-test confirmed there is a statistical difference between the proportions of time spent on training as a percentage of non-billable hours for SIL providers when compared to non-SIL providers at the 1% significance level. However regression analysis Exhibit indicates that there no statistically significant relationship proportion revenue from services and time spent on training as share billable hours It may be drivers spending were well captured specification However additional failed find better suited model

|Regression variables | Mean | Median | 5th percentile | %7h percentil| |- |- |- |- | |SIL provider indicator |0.|0.|4.- -||% Percentage Revenue Sourced From SIL |0.|6.%- Number Clients (log) -3-.0%-<– 2nd line should start with - Supervisors log)-0.>-0-& Direct Staff (log)|0.|0.|0.|0.|R²|18%.22-%21%%1.3% Note: and indicate variable threshold respectively observations).

Supervision costs

The NDIS Disability Support Worker Cost Model recognises staff require direct supervision care management support They key parameters associated supervisor conditions This section considers material differences between settings The key questions Review Issues Paper are:

T-test compared mean time spent percentage non-billable hours providers offered SIL services n=200 providers did not offer SIL services P-value right tail test was indicating that had greater than at significance level.

Additional included overhead as a of total direct costs Direct Costs permanent employment rates Equation regresses the labour time DSWs employed by against: The SIL provider indicator variable (`if deliver, otherwise); Percentage revenue sourced from Log number participants supported by Log FLSs employed by Log Number DSWS employed Average base wage paid to FLSs and average base wage paid to DSWS employed by .

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Is there a material difference in the wages and on-costs of supervisors between SIL services and non-SIL services? If there is a difference, what are the key drivers of these differences? How large is the difference?
Is there a difference in the supervision ratio (the number of workers per supervisor) between SIL services and non-SIL services? If there is a difference, what are the key drivers of these differences? How large is the difference?

Base Wages – Supervisors

There is some evidence from the Financial Benchmarking Survey that SIL providers may pay higher base wages for supervisors than non-SIL providers (Exhibit 21 and Exhibit 22).

Exhibit 21: Box Plot - Base Wages of Supervisors

[Image not converted to Markdown – “Box plot showing distribution of base wage ranges” – check the source PDF page for the actual content] note: Data labels for the 25th percentile are shown to highlight the efficient frontier within each category.

Exhibit 22: Summary Statistics – Base Wages of Supervisors

Respondent type	Sample size	Mean	Median	25^th percentile	75^th percentile
All respondents	`846`	`$38.40`	`$38.50`	$33.80$	$42.50$
Non-SIL respondents	`625`	`$38.21`	`$37.74`	$33.75$	$42.49$
Mixed (`SIL/ADL`) respondents	`221`	`$38.89`	`$38.74`	$34.99$	$42.49$
-% SIL respondents	`81`	`$38.16`	`$37.24`	$34.00$	$42.49$
26-*-% SIL respondents	`47`	`$38.85`	`$39.24`	$34.76$	$42.49$
5%-***% SIL respondents	`64`	`$38.83`	`$38.86`	$35.39$	$42.45$
%-*% SIL respondents	`29`	`$41.14`	`$40.88`	$38.58$	$43.09$

Regression analysis (Exhibit 23) confirms that there is a positive relationship between the proportion of revenue from SIL services and the average base wage paid to supervisors. on-average, the base wages of supervisors in efficient (<sup>th</sup> percentile) SIL settings are $$$ per hour – higher than in non-SIL settings.`

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that supervisor wages increase with the log of the number of clients serviced bythe organisation but decreasewith thenlogofthenumberofof staff employedbythetheorganisation. The analysis also indicates other statistically significant relationships that average wagepaidtosupervisors increases withe the log o fnumberclients provider and log of th e number oft he staf t osupervisor ratiobut decreases as them nbersthat a supervisorexpectedtosuperviseincreases.These could be further investigatedon structural differences tobawages supervisorsSIL organisationsandother variablescould describethiss difference due to low R² (variables in model do not explain basewage sot super visors well).

Exhibit Regression Analysis – Base Wages Supervisors¹⁸

|Regression variable | Mean | Median | 50% percentile | |- |- |-| | SILprovider indicator | 467893210-0:04 | -0.0 | -0.89** +-0.63* + +-2.72 ++2.23||R² ||4.6% +++3.7% ++++2.9% ++++++++4.0% +Note:*indicatesvariable issignificantatthresholdrespectively(observations).\Supervision ratiosThereism some evidence from Financial Benchmarking Surveythatsupervisorsin SILEsettings have higher spans controls than non-SILE settingsExhibit 24 Exh ibit There are evidencethatsupervisorsinsile settingshavehigher spansofcontrolthan insilsettingsexhibits andexhibitionsshowsthatthespanof controlislowerinthesettingsthansilset tings. supervisorsonnonSILsettingshaveanaveragespan of controlofto while supervisors in mixed silADLsettings hav an average span o fcontrolof A similar difference apparent amongst efficient providers where the spantoand respectively However regression analysis indicates that once differences numbers clientsnumbers staff per clientutilisation skill level supervisions controlled for there no statistically significantdifference levelsstaff supervisor ratio between SIL and nonsil providersexhibit This finding aligns with survey results AbleInsight surveymaterial differen cesbetween Silandsnonsilproviders 18 The equation regressesthe average base wages supervised byprovider against:•The SIL provider indicator variable (if deliver s IL otherwise); •Percentage revenue sourcedfromsil; Log number participants supportedby provider; Lognumber DSW employed by provider; andLogratio FLS headcount)DSWs(head countemployed by provider. |

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Exhibit 24: Box Plot – Supervision Ratio

Note: Data labels for the 25th percentile are shown to highlight the efficient frontier within each category.

Exhibit 25: Summary Statistics - Supervision Ratio

Respondent type	Sample size	Mean	Median	25^th percentile	75^th percentile
All respondents	`redacted` (N=3)	`-0,6*`	-0,-1***	-0,.07	-.1*
Non-SIL respondents	N=3	`.03` * .01 ***	`.01`	.03	.08-
Mixed (`SIL/ADL`) respondents	N=9	.01**	-.01***	-0.

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Overheads

The NDIS Disability Support Worker Cost Model recognises that providers incur a number of costs (“overhead s”) that are directly attributable to worker salaries and other overheads. This section considers whether there material differences in overhead cost between SIL settings compared non-SIL settings The key questions for review were:

Is difference level corporate overheard incurred delivering services? If so what aspects driving difference? How large does differnce?

Figure: Box Plot – Overhead Costs Note: Data labels shown highlight each category type revenue sourced from;Log participants supported base wage paid FLS employed Average ratio DSWs employed provider participant labour time spent billable work DWS employed provider.

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Exhibit 28: Summary Statistics – Overhead Costs

Respondent type	Sample size	Mean (%)	Median (%)	`5th` percentile (%)	`75th` percentile (%)
All respondents	551	35.	*32.0%	20.%	46.%
Non-SIL respondents	379	35,.5%	31,.2%	20,%.0%	46,.8%
Mixed (SIL/ADL) respondents	172	34,.,3%	33,.,%,1%*	21,,4%	44**,,,3%
O-25% SIL respondents	63	35,.,7%	33,.,9%	21.,%	******************45,,,,0%
26–50% SIL respondents	39	38,.,1%	34,.,9%	24..1%	**************************52,,,,,,,,3%
51–75% SIL respondents	48	33,.,7%	31,.,6%	22.,1%	**********************************45,,,,4%
76–100% SIL respondents	22	24,..%	21,.,2%	19*.3%	********************************************33,….%.

Regression analysis (Exhibit 29) shows that there is no systemic difference in overheads between SIL and non-SIL providers as the coefficients of both the SIL provider indicator variable and the percentage of revenue sourced from SIL variable are not statistically significant different from zero. This finding holds both on average and for efficient providers. The statistically significant relationship that can be observed in the data with respect to the direct cost per client (log) variable and the average base wage (DSW) variable is not unexpected as overheads are, in general driven more by headcount than individual worker rates so when wages increase overall costs decrease but this does not necessarily mean an increase or reduction over a period time frame due to other factors such as inflation etc…

Exhibit 29: Regression Analysis – Overhead Costs²⁰

Regressor variables	Mean (%)	Median (%)	`25th` percentile (%)
SIL Provider Indicator	--0,.,%,1***	-,,%-	-,-,.4
Percentage Revenue Sourced From SIL	+,.,%	-,+,.6****	%
Number Clients (Log)	+.%.**	*.%%%%%%	.%%%

The equation regresses log ratio between overhead costs provider against: • The SIL indicator variable (if provider delivers sil otherwise); • percentage of revenue sourced from Sil; • square root of number clients supported by providers.

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Supply Costs Specific To SIL Services

To test whether there were any supply-cost considerations specific to delivering SIL services not accounted in current NDIS Disability Support Worker Cost Model, a review sought evidence about these costs’ drivers. In particular: The Issues Paper asked responses regarding following questions:

Vacancy Rates: What’s average vacancy rate across properties? is it influenced factors like participant complexity per property, rurality & room count within each property? factors considered optimizing participants per SIL property? impact costs have this optimization approach used optimize vacancies levels?
Vacancy Costs : How do vacancies affect delivery cost of SIL service? quantiyze these costs your organization some fixed associated with vacancies - inactive sleepover same cost regardless two or three residents; some variable costs managed through rostering changes; what proposition is fixed vs Variable Vacancy Costs in org?
Participant Complexity: Impact does participant complexity on supporting costs in SIL environment? optimize allocation different support needs across properties?
Shift Costs: Number shifts provided 24-hour period driven by number participants, mix supports needed the property other factors? Sleepovers and crossover impacts? on supply costs?
Establishment Costs: Annual basis how often new established into propertys? difference exists between establishing SIL non-SIL services if so aspects driving difference? large that difference influence complex participant’s needs existing numbers rooms, etc.? or other factors.
Location Differences: Significant differences exist delivering SIL services metropolitan centers versus regional rural remote areas? average cost differential elements drive this difference?
Other Supply Costs: Proportion Disability Support Worker time spent providing to participants includes: pct labour time billable work DSW employed provider log ratio FLSs (headcount) & DSWs headcounts employed provider average base wage paid FLSs employed provider avg based wages for DSWS employed providers.

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directly interacting with participants as well tasks which don’t involve direct interaction such preparing meals sleepover shifts.

Vacancy rates costs

Financial deep dives conducted Deloitte provided data vacancy rate mean occupancy percentage median proportion vacancies Alliance20 nine providers indicated average SIL Ability First received similar numbers members being .
Vacancies incurred when house operating at full capacity residents/participants supported in its arrangement response Issues Paper reported organisational level between Some suggested zero close to zero Ability Roundtable organisations had an average vacany rate around days for participants needs day participant with high intensity needs significant variation length time tended persist from Ability First data was about days for participants need number rooms property cited important but less factors respondents reported individual property level between % fixed because related irremediable minimum staffing level so were affected presence vacant ability first also showed management contributed Standard High Intensity overhead further cost risk review however that discussed above financial Benchmarking Data does not show any statistically difference overheads between and non-SIL settings.

Participant complexity consensus consultations submissions increased delivering supports environment most commonly raised impacts training staff supporting higher needs more qualified or experienced staff owing work carried out turnover billable supervision greater complex participants these already recognised NDIS Disability Support Worker Cost Model varies parameters according whether has high support hourly price limit standard is times than the price limit for standard support. Review acknowledges providers planners do always agree on calculating cost of a roster care using either standard or high intensity limits while this affects value plan it pricing issue considers matter best addressed through Operational Guideline for SIL.

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Shift Costs

Weekday Support

A Weekday Daytime Support, which 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 Public Holiday Support or a Night-time Sleepover Support); or
A Weekday Evening Support, which is any support to an individual participant that starts after 8:00 pm and finishes at or before midnight on a single weekday (unless that support is public holiday Support or night-time sleepover Support);or
A Weekday Night Support,whichisanysupporttoanindividualparticipantthat commencesatorealmidnightonaweekdayandfinishesaftermidnighthownthat week day , orecommence sbefore redacted*amonaweekdaysandfinishsontheweek- (unlessthattsupportispubl iholidaySupport, SaturdaySupp ort,Sunday Suppo rtoraNight-t im eSleepo verSu p port). Additionally,supportsinSILmayalsorelatetothenight-timesleepoversu pportwhenaworkerisa l lowedtosleepphile notdeliveringsuppor t. Anighttimesleep oversupp ortingisanys upports tore ndividualpartic ipantdeliveredoneaweekday,aSaturday,aSundayorasPublicHolidaytha t: • commenc esbef oremi d nigh tonagiven da y anda fin i shes afte rmi di nghnon th aday; an d • isi foracon tinuousperiodofeight( )hoursormore;a nd • theworkeraisallowedtossleepwhentheyarenotproviding support. Forpricingpurposes,supportsprovidedonas Public Holiday Sat urd ayor Sunday are claimed at therelevantrateasthecostsd onotchangebasedonthetim eduringthatdayit is delivered .Submissionsindicated thatmostprovidersdidinfactuse3shiftsp er24hour period.Generallythesplitwasamorning-afternoon shift ,afternooneven ingandovernightsleepover s hift.However,asubstantialminorityreported-6 shifts andafewhad78shif ts.Several providersmentionedthistishighlydependentonparticipantsupportneeds.Thefinancial deepdivessubmittedtoDeloit teAccessEconomics,hada mean ofredacted shiftsandamediano f *3 shiftsper24 hour per iod*( 7 respondents). slee poverswereraisedasanissuewhenverthe participantisactive overnight asthen providerhasto paytheworkerforanactiv eovernightshift notjustthesesleep overallowanceasperAward. Theunpredictabilityofparticipantsparticularlypartic ipantswithhigher needscancaus high supply costs forsleep oversanda crossovershiftsgiven higher overtime rates needing to be paidt o theworker(asper Award).Howeverprovid ers argued these impactsarenotnecessarilyfundedintherosterOfCare Thissuggestssuch concerns arebetteraddressedthroughplanningaspri ng mechanisms do no thinder recoveringcostswhensu ch support isdelivered .TheReviewnotes that thenDISPriceLimitform Night-TimeSleepov er supports includes two hours oft ottime suppor t provided during this time with third anda dditiona lhours tob e claimedasa rtesstipulated inNDIS Price Guide Potentiallythiscouldleadtohigherp ayments thanifthes hifthadbeen activeovernight So whileSILworkersmayhave more

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interrupted sleeps than their community activities of daily living counterparts, providers should still be effectively reimbursed if claiming correctly. The Review acknowledges that providers and planners do not always agree on whether the cost of a SIL roster of care should include an active overnight or sleepover supports. While this affects the value of the SIL plan it is not a pricing issue and the Review considers that this is a matter best addressed through the Operational Guideline for SIL.

Location differencesThe majority of respondents to the Issues Paper suggested there was greater cost providing SIL supports rural remote areas than metropolitan areas This mainly driven by difficulties attracting retaining staff potential length vacancies ruralsil arrangementsThe Review notes However both NDIS Western Australian Market Review 2019 ndis Annual Pricing Review concluded no compelling evidence increase regional price limits versus metropolitan limitReview also note that remote veryremote price limits already higherthan metropolitanslimitThis Review considers workforce concerns may better addressed through non-pricing mechanisms In particular issues arising general rural regional workforce shortages dealt larger workforce initiatives such Boosting Local Care Workforce Program

code{https://blcw.dss.gov.au/}BoostingtheLocalCareWorkforceProgramBLCWProgramfundedbyDepartmentSocialServicesdeliveredErnstYoungFirstPeoplesDisabilityNetworkAustraliaandthi

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Other Costs

Respondents noted maintaining registration with NDIS Quality & Safeguard Commission is costly due to time-consuming audits; some supervisors spend half-time dealing directly. Organizations engaged staff specifically for quality/safeguards compliance tasks which are significantly more demanding than daily activities in SIL settings (e.g., managing incidents related external interactions). The Review notes these costs have already been addressed within overheads/utilization rates analysis above, suggesting differences between SIL/non-SIL will be captured under utilisation rates/overheads.

Conclusions

The Review has found that there is evidence to suggest that compared to activities of daily living delivered in a non-SIL setting by an efficient provider, an efficient SIL provider faces:

higher rates of permanent employment (η5.μ% compared to οξ.%);
higher workers compensation premiums (.4% to .%; higher average utilisation rates (% compared t %);; higher base wages for supervisors (%) and;\highe annual leave costs associated with great leav entitlement ( weeks per yearcomparedto weeksperyear). someof these effects addtostthecostservice provision whereas others reducethat cost.The net effect, as Exhibit showsis thathfully loadedcosts serviceprovisioninSILandnon-SIsettingsareessentiallyidentical.Exhibit Efficient Costs in SIl and Non-Sl Settings TheReview therefore does not recommend any changes int he current SIIPricing arrangements.Therewiewacknowledges that vacancies can present issuesfor providersas expenditureisan always able be adjusted linewithchanges revenue.Reviewdoesnot consider this to be deficiency unit price limit but rather planningarrangements which do not adjust participant plans maintain supports responsevacancies.If example three people house being funded 24/1: support there is vacancy then the Review acknowledges number worker cannot reduced.

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since all of the participants have been identified as having a need for 24/7 support. The problem is not, however.with.the.unit.price.paid.per.hour.of.support but rather than.a.change circumstance means that funding.in.two.remaining.participant’s.plans has no longer being appropriately determined.to meet their reasonable.necessary needs. If.vacancies were relatively uniform across sector then it would possible adjust unit price vacancy risk.However.available data does indicate uniformly distributed so this issue best address through plan review.rather.than through.changing pricing arrangements.Because.plan.reviews can take some.time occur may be.appropriate.when vacany occurs.providers ability claim applicable ratio supports remaining receiving.SIL period after vacant allows flexibility will assist providers immediately recover rostered staff costs when vacancies occur.Any such arrangement would managed carefully reduce incentives.fill vacant could done restricting time which provider bill reminding higher at.such allowing providers to remain more when vacancies exhaust plans sooner anticipated sensible undertake change circumstances review affected SIL arrange This will assist coordinating funding amounts ensure they have support continuity shared in aligned each other.The also recognises providers required continue provide existing resident participant during period plan review there therefore risk providing different ratios eventually approved part plan review.Review considers strong arguments by.provider NDIA if.NDIA complete planning within agreed timeframe should entitled paid until plan completed.review The recommends Operational Guideline for SIL reviewed:

clearer advice on the circumstances high intensity and sleepover/active overnight included in SIL plans; for changes of circumstance reviews material impact cost delivering participants settings;and guidelines.agreed timeframes plan review SIL greater certainty about revenue not. certified.completed.billing issues addressed appropriate timeframe.

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Document: MR25/01967 FOI 24/25-2242

NATIONAL DISABILITY INSURANCE SCHEME REVIEW OF SUPPORTED INDEPENDENT LIVING PRICE CONTROLS ISSUES PAPER AUGUST 2020

Delivered by: National Disability Insurance Agency

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Copyright

Copyright in the information contained in this document is owned and protected by the National Disability Insurance Scheme Launch Transition Agency (National Disability Insurance Agency).

Issues Paper

The National Disability Insurance Agency (NDIA) has released this Issues Paper seeking inputs to inform the cost parameters required to estimate the fully loaded cost of delivering an hour of personal care in a shared living arrangement. The issues paper invites submissions from providers of SIL services and impacted stakeholders on a range of issues which will be considered in developing price limits for SIL services. Individuals and organisations should not feel restricted to comment solely based upon matters raised within these papers.

Key date

Due Date: Sunday, October 25th @ midnight AWST, Submissions may also be submitted via email: Pricing@ndis.gov.au

Contact details administrative other matters:

Contact Centre: Monday - Friday | Hours:8am – 6pm (local time) Phone Number: +[phone number] Email Address:[email address] Website Link:[website link] Further Information can found at link. Terms that we use include: | Abbreviation | Description | |- |-| | NDIA | National Disability Insurance Scheme Launch Transition Agency (“)National Disablity InsuraceAgency”)"(“) | NDIS | National Disability Insurance Scheme \” | SIL | Supported Independent Living "

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Introduction … page number not provided in text but typically follows definitions.
Definitions ….. [page_number]
Responding to the Review…..[page_number]

Issues for Participants…….[page_number]

Wages and on-costs……. [page_number]

Workforce mix…… [page_number]

Utilisation…………… [page_number]

####### Supervision cost ………. [page_number] ######## Overheads ……………… [page_number] ############ Supply costs specific to SIL services……….[ page_number] ################ Other costs……………..[page_number] *** Appendix A:** Schematic overview – NDIS Disability Support Worker Cost Model ……. [page_number] **** Appendix B: Current arrangements……………..[page_number]/1049

Introduction

One of the principal objectives of the National Disability Insurance Scheme (NDIS) is for people with disability to exercise choice and control over how, and with which providers, they spend their available budgets. The role of pricing in the NDIS is therefore very important. Prices, or more precisely participants’ choices in response to the prices they face in themarket, reflect the preferences and relative values that different participants place ondifferent types of supports. The aggregation of these individual responses in turn signals toproviders the quantity and mix of supports to supply. Prices also affect the purchasing powerof participants. Higher prices reduce the supports participants can purchase within agivensupport budget. Prices also affect the total costs of the NDIS and therefore its financialsustainability, and the allocation of resources to the NDIS (and therefore possibleproduction), relative to other sectors. Pricing can also affect providers’choices,includingby providing incentives:–for enteringthe market;forsupskillingandrigh-skilling;﬎;for innovation;ﻯorimprovementsinservicequalityandooutcomes. asmarketstewardforthedisabledisabilitygoodsandservicemarketsdevelopandeffectivelyoperate, devicesmoreeffectively,theNationalDisabilityInsuranceAgency(NDIA)🎖🙇 willbeabletobelessinterventional.However,deregulation will necessarily occur at differents points intime for diferentmarketsmaynot befeasiblein somecases.CurrentlythetNDAIavariesitsapproachtotheregulationpricesbetween:•No regulation(dereguated markets):this appliesincaseswheremarketsare highlycompetitive—for exampletransport.•The imposition price limits these represent maximum allowablepricepayable byparticipantsfortypessupports.This approachapplies in significant numberofmarkstransportwhich are still developing growing such as those attendant care •Quotablesupportsin which participants expected obtain quotations fromsuppliers provide NDIApartverifying prices fair reasonableThis typically apply case of high specialised differentiated supports that may not havehigh level competition—example assistivetchnology.The NDIS Disability Support Worker (DSW) Cost Model is one methodology the National Disabiliy Insurance Agency uses to inform its pricing decisionsforthose deliveredby DisabilitySupport Workers on it imposes price limitscopyModelatlinktoschematoAppendixA.On 1 July2020, replaced previous quotationpricingarrangements Supported Independent Living with based ‘assistance self-care’ supportschanges made supported independent living were designed increase transparency equity how SIL funded simplify administratively complex processes. NDIA committed improvingtransparency fairnessprocesses decisionmaking and conducting review price controlsSupportedIndependentLivingoutcomes come effect later yearReview tasked suggestingimprovementsstructurethe

Review of Supported Independent Living price controls

identifying whether there are different costs that arise in the delivery of attendant care supports in a shared living arrangement that do not arise in other settings;
quantifying any differences that may be required in the key parameters of the NDIS Agency’s Disability Support Worker Cost Model for attendant care supports in sharing living arrangements, given the different cost structures of delivering supports in shared living arrangements compared to other settings. The NDIA is seeking input from the sector and interested parties to this Review to inform the insurance disability scheme sustainability.

Disclosure Log

Review of Supported Independent Living price controls

utilisation (non-billable activities); employee allowances; corporate overheads and margin. These estimates are the basis of the price limits set by the NDIA for supports delivered by Disability Support Workers. In adapting the NDIS Disability Support Worker Cost Model to set price limits for SIL services, there are a number of aspects of the Cost Model that may need to be adapted or refined. The following sections outline the key areas and invite feedback from providers on a range of targeted questions. Some of these areas relate to differential supply costs for delivering non-SIL compared to SIL services, while other areas relate to cost drivers that are unique to providing SIL services. Providers are also welcome to provide feedback on any other issues that they consider relevant to this review. Providers are encouraged to refer to or send in data and/or evidence to support statements that are made in responding to each/any of the questions. This includes any applicable cost models for relevant SIL services. Information marked as commercial-in-confidence will not be published. Submissions can be lodged by email to: Pricing@ndis.gov.au . Submissions must be lodged by Sunday, 25 October 2020, 11:59pm AWST.

Confidential submissions

Submissions to the Agency that are marked as commercial-in-confidence will not be published.The NDIA has engaged Deloitte Access Economics to assist the Agency in undertaking this review. If preferred, respondents may give confidential information, including commercial-inconfidence data/information, directly to the team from Deloitte Access Economics at SILpricingreview@deloitte.com.au. This information will not be provided to the NDIA unless the submitter gives their consent, and any reference to this information by Deloitte in their reports to the Agency will maintain the anonymity of the source.

Issues for Participants

Under the quotable support arrangements for Supported Independent Living that were in place before July 1st, 2020, participants did not always have high degrees of control over their group house’s offered services.

The agency aims at empowering these participants more involvement selecting reasonable necessary supports who assist them daily activities home simplifying process providers changes pricing arrangement made July 1th 2020 supported independent living designed increase transparency equity funding SIL supports simplify administratively complex processes implementation price limits operational changes guidance also released participant involvement understanding their SIL supports aim consultations understand move from quotable supports prices may impact on experience engaging service providers receiving within a supported independent living environment potential impact prices might improve choice control Your views will considered review reflected reports developed during this process:

What do you consider as advantages disadvantages regarding new approach supported independent living? Are there particular factors Agency should aware defined costed charged to participants?

Issues for Providers

Wages and on-costs

The NDIS Disability Support Worker Cost Model recognises that wages and on-costs are the largest cost driver for providing disability support services.

The NDIA therefore seeks detailed evidence regarding material differences between base hourly wages paid: to - Workers with SIL status vs those without, on-costs associated:with both groups.

Base Hourly Wage

Base hourly wage refers to minimum pay rate received per hour excluding shift/leave loading/superannuation allowances. Salary On-Costs include superannuation/workers compensation premiums/payroll tax/employee allowance costs.

Is there a Material Difference?

Is there any significant variation in base (minimum) hour rates among staff performing SIL tasks versus other roles? Does such disparity reflect varying training needs/nature of work or another factor? If so how substantial does it appear?

Salary On-Cost Differences

can workers delivering SIL services incur different salary-related expenses compared others not involved directly within this service type? The reasons behind these variations, along with their magnitude should be identified if present.

Overtime Costs

do you notice notable distinctions when comparing overtime expenditure levels across employees engaged specifically as part of SIL delivery against non-SIL counterparts? What specific aspects differentiate each role necessitating differing expenditures here? How large is that difference exactly? ####### Leave Cost Variations Are leave cost allocations distinct for individuals working on SIL projects relative to colleagues who do not participate actively under the same umbrella? Identify what factors lead towards disparities and quantify them accordingly, to understand scope fully.

Enterprise Bargaining Agreements (EBAs)

is your organization currently implementing an EBA covering some/all its workforce: does the agreement’s terms vary between those providing direct support through SIL activities vs. general duties elsewhere without involvement therein? If differences exist explain why they occur and assess scale.

Disclosure Log

Review of Supported Independent Living price controls

Workforce mix

The NDIS Disability Support Worker Cost Model recognises that the costs of employing casual and permanent workers are different. The NDIA is therefore seeking detailed evidence on whether there are material differences in these arrangements between SIL (Supported Independent Living) workers and non-SIL workers.

Casual staff

Question: Is there a material difference in the proportion of employees employed on a casual basis? between employees providing SIL and non-SIL services? If there is a difference, Which aspects of SIL service delivery are suited to more or fewer) to which aspects relative to casual employees?) persistent employees? How much larger is it than those for full-time employees?
Question: What Is the average number per week hours that an employee member is casually employed your organisation? in your organization?
Question: Is There A Material Difference In The Average Number Of Hours Per Week That A Casual Staff Member Is Employed In Your Organisation Between Employees Providing Sil And Non-sil Services? If There Is A Difference, How Large Is This Difference?

Part-Time Staff

What Is The Average Number Of Hours Per Week That A Part Time Staff Member Is Employed In Your Organization?

Disclosure Log

Review of Supported Independent Living price controls

Level of Staff

Q: What level of worker do you use for standard vs higher requirements, and when do you decide if a participant requires higher-intensity support?

Utilisation

The NDIS Disability Support Worker Cost Model recognises that staff need to spend some working time undertaking non-billable work, including breaks and training. Therefore, we seek information about any significant variations regarding this arrangement among SIL (Supported Independent Living) service providers.

Training Requirements

Question: Do training needs – along with associated costs - differ between SIL Services versus Non-SIL Services? If so,

What factors drive such discrepancies;
Which aspects require more or less intensive training; How substantial might be those disparities?

Question: Are initial training demands different in terms both of content as well as cost-wise across new hires within these two categories: SIL services against their counterparts at non-SIL facilities? Similarly here too please provide insights into what drives said differences alongside quantifying them where possible!

Other Non-Billable Activities

Is there an observable difference concerning the indirect care tasks performed by personnel operating under either type of service model compared e.g., shift handovers & individualized note-taking etc.? If yes then explain why they vary how much exactly?

Supervision Costs

Staff must receive direct supervision while providing care which also includes managerial oversight per NDIS guidelines. Key parameters related specifically towards supervisory roles include remuneration conditions coupled together with ratios thereof. Henceforth, further clarification is sought on whether notable distinctions exist amongst staff employed for respective purposes i.e., SIL vs regular settings.

Supervisor Wages and On-Costs

Does a disparity prevail when comparing supervisor salaries plus ancillary expenses incurred during employment among individuals working exclusively inside SIL setups vis-à-vis standard operations? Should any distinction arise, it should elucidate underlying reasons behind such variations alongwith estimating magnitude involved accordingly.

Disclosure Log

Review of Supported Independent Living price controls

Supervision ratio

Question: Is there a difference in the number of workers per supervisor for SIL services compared to non-SIL services? If there is a difference, what aspects of service delivery mean that more or fewer supervisors are required How large is the difference?

Overheads

The NDIS Disability Support Worker Cost Model providers incur overheads (costs not directly attributable worker salaries). The NDIA seeks evidence if these differ between SIL & non-SIL.

Corporate overheads

Question: Is corporate overhead different when delivering SIL vs Non-SIL Services ? If so, what drives it how much larger/smaller?

Turnover rates

Do staff turnover vary among those who deliver SIL and non-SIL, why/how big/why smaller/larger differences exist? What costs arise from this turn-over? Do they also change based on type of service delivered? Why do they differ and/or how significant? Supply Costs Specific To SIL: NDIA recognizes specific supply cost considerations for providing SIL services; seeking detailed info about them and their drivers. Vacancy Management: 25) What’s your average vacancy rate across properties 26) Does property vacance depend complexity participants rurality rooms? How does optimizing participant numbers affect costs? Approach used optimize vacancies across all properties?

Disclosure Log

Review of Supported Independent Living price controls

Vacancy Costs

Question: How do vacancies impact the costs of delivering SIL services? Please quantify these costs for your organisation.

**Answer: Some costs associated with vacancies can be considered fixed – e.g., an inactive sleepover in three-bedroom house has same cost whether there are two residents (e.g.) What proposition(s) regarding vacancy costs being either ‘fixed’ vs variable exist within your organization?

Disclosure Log

Other Costs

Question: Is there an additional cost involved with non-SIL and/or SIL services that isn’t included within our current model? Please supply further information.
Question: Any extra expenses due to COVDID-19, Please give more detail.

Appendix A: Schematic Overview - NDIS Disability Support Worker Cost Model

Parameter	How Is This Reflected in The Cost Model?
Base pay & Shift loadings & Leave allowance On-costs Supervision costs Permanent workforce Utilisation Overheads Margins Indexation	Four DSW levels (23/26) based on SCHADS classification Applies a loading for permanent staff working weekends, public holidays afternoons and nights applies casual loading for weekdays weekend public holiday afternoon night Includes annual leave personal leave public holiday long service leave Superannuation workers compensation employee allowance Supervisor to DSW ratio of 70% Incorporating breaks training other Varies across staff level Assumes direct cost Assumes % margin Fair Work Commission Equal Remuneration CPI

Parameter

How Is This Reflected in The Cost Model?

Base pay & Shift loadings & Leave allowance On-costs Supervision costs Permanent workforce Utilisation Overheads Margins Indexation

Four DSW levels (23/26) based on SCHADS classification Applies a loading for permanent staff working weekends, public holidays afternoons and nights applies casual loading for weekdays weekend public holiday afternoon night Includes annual leave personal leave public holiday long service leave Superannuation workers compensation employee allowance Supervisor to DSW ratio of 70% Incorporating breaks training other Varies across staff level Assumes direct cost Assumes % margin Fair Work Commission Equal Remuneration CPI

Appendix B: Current arrangements

The Supported Independent Living support items in the NDIS Support Catalogue provide participants with assistance with, or supervision of tasks daily life shared living environment focus developing skills each individual live autonomously possible The support provided person living arrangement accordance need. These supports can be delivered participant subject rules set out NDIS Price Guide . as well direct service provision these support items used claim Non-Face-to-Face Support Provision Provider Travel and Short Notice Cancellations Providers also claim non-labour costs Provider Travel Different price limits as follows Table apply depending Time Day Week delivery whether High Intensity Supports.

Disclosure Log

Review of Supported Independent Living Price Controls

This disclosure log relates specifically to reviews and evaluations concerning supported independent living pricing mechanisms.

The document has been disclosed in accordance with Section 35 of Australia’s Freedom of Information Act (”FOI”), enacted during “the year marked as ‘1982’ within its title,” which pertains directly towards ensuring transparency regarding government operations or decisions affecting public interest areas such as disability insurance policies.

Disclosure Log

FOR OFFICIAL USE ONLY

DOCUMENT 46

**ndis Delivered by the National Disability Insurance Agency.

Pricing Reference Group Meeting: May 13th - Minutes

Date: Thursday, April 5071
Time: 10am – 1pm
Location: Microsoft Teams

Members


Pricing Reference Group Members:
Deborah AM Independent Member Graeme AM Independent Member Jim PSM Independent Member Julie PSM Independent Member Lynne Personal Privacy Independent Member Participating Observer nominated by CEO Lisa DCEO Markets Government Engagement Scheme Actuary Sarah Chief Economist David Cullen Secretary Director Pricing Operations Price Regulation Unit

Declaration of Conflicts Interest The PRG NOTED that register members’ interests were noted in the minutes from previous meetings.

The PRG ENDEDORSED those notes on the minutes for meeting held previously (PRG Minutes of Meeting dated March 28). All actions arising therefrom had been closed out as well. Update by chairperson was given regarding recent developments within NDIS. Financial Benchmarking Survey update provided by David Cullen, Chief Economist. Discussion ensued over preliminary findings presented during this survey which led to agreement among group members about undertaking a financial benchmark review for FY20/21 with consideration being extended towards including support coordination providers therapy ECEI providers non registered providers subject materiality test.

Disclosure Log

Pricing Reference Group Meeting: May 23/5-2242 Minutes

consideration should be given to options to increase the response rate to the survey including increasing value provided an individualised benchmarking report each completing their key metrics peers.

Review Of Therapy Arrangements For Supports

The paper Item - Item presented PRG Chief Economist David Cullen discussed paper agreed recommend through CEO subject further investigating statistical differences between psychologist other therapist price limits therapy supports based results so that: o An hourly limit $ applied therapeutic supports audiologists podiatrists physiotherapists psychologists occupational therapists speech pathologists; o An hourly limit is applied therapeutic supports audiometrists art therapists counsellors development educators dietitians exercise physiologists music therapists orthoptists rehabilitation counsellors social workers teachers; The hourly prices not adjusted terms and current rules non-face services, writing provider travel cancellations loadings remote very areas maintained Board consider phasing transition new pricing arrangements otherwise ensure no unnecessary disruption access support participant.

Disclosure Log

Pricing Reference Group Meeting: May 13th - Minutes

Review of Pricing Arrangements for Supported Independent Living (SIL)

The paper “Item 3.2” titled ‘Review of Pricing Arrangements’ was presented at PRG meeting on April 5/7.

The PRG discussed this item: * No changes should occur regarding SIL pricing arrangements as no evidence suggests significant differences between efficient costs within a non-SIL setting compared to an existing arrangement; * As part of next Annual Price Review due mid-year, the NDIA must collaborate closely in examining operational cost impacts from vacancies among service providers along with claims related to vacated dwellings if insufficient notice is given after participant departure; * Cost analysis will also include compliance requirements under Commission’s reporting guidelines ensuring these are appropriately accounted through Disability Support Worker Cost Model; * Repeat comparative analyses similar those conducted during financial benchmarking surveys completed earlier years, focusing specifically upon participants requiring complex needs support services provided via Registration Groups and Coordination Services; © Further improvements needed concerning administrative processes including clearer advice about high intensity supports inclusion criteria into Service Plans; greater certainty around revenue when plan reviews or billing issues aren’t addressed timely; developing enhanced programmatic solutions aimed towards reducing burden & improving outcomes by October first year ahead.

Pricing Arrangements for Support Coordination

The paper “Item 3.2” titled ‘Pricing Arrangement’ was submitted prior the same date at PRG meeting on April 5/7. The PRG discussed this item:

Subjected mitigation strategies addressing transitional concerns, price limits should be reformed as follows: * Decommission Level I: Connection Item while assigning Local Area Coordinators (LACs) responsibility of delivering such services, lowering current limit set forth in registration group 106 regarding coordination service delivery to match psychosocial recovery coaches’ rates; * Reformulate available items within registration groups related directly with providing specialized care tailored toward highly demanding participant requirements ensuring two distinct levels exist per provider type offering these specific types of assistance.

Disclosure Log

Pricing Reference Group Meeting: May 13, 2021 Minutes

A new Level 3 Support Coordination price limit equaling therapy’s is proposed for supports needing specific therapist skills.

Noted:

The PRG noted that if accepted changes are made in pricing arrangements, it intends participants currently funding plans will continue using support until next plan review (Level I). For Levels II & III coordination would reduce remaining funds proportionally or based mix found reasonable/necessary at their reviews respectively.

Item 3.4 - Pricing Arrangements For Group Based Supports

The paper “Pricing Arrangements” was presented to the PRG by David Cullen Chief Economist The PRG discussed this item agreeing it should be recommended through CEO:

Extend transitional core group support prices another year while reviewing unintended consequences including overhead costs/administrative complexity affecting providers/families; with a comprehensive review part of Annual Price Review scheduled first half ’21-’22;
Do not index current transitional group support limits on July 1st and reduce real terms from June-July 5th/6th groups’ limits as an incentive transition to newer arrangement;
NDIA facilitate sharing best practices among those transferring successfully between old/new arrangements.

Temporary Transformation Payment TTP

Paper about TTP also presented by David Cullen, Chief Economist The PRG agreed there’s evidence reasons behind introducing temporary transformation loading no longer apply and merit phasing out rather than immediate withdrawal considered three options compared against four-year trajectory reducing limit sequentially: setting loadings zero starting Jul ‘21, a twelve-month path ending in Jul ’22 splitting into two annual steps (3% &0%), an eighteen month plan finishing Jan’23 split across six monthly increments.

Disclosure Log

FOR OFFICIAL USE ONLY

Pricing Reference Group | Meeting: 13 May 2021 Minutes

PRG AGREED TO RECOMMEND THROUGH THE CEO THAT TTP Loading SHOULD BE WITHDRAWN MORE RAPIDLY THAN INITIALLY INTENDED, WITH PHASING CONSIDERING BALANCING SUSTAINABILITY AND DISRUPTION TO BUSINESS PLANNING. THE PRG DID NOT SUPPORT IMMEDIATE WITHDRAWAL OPTION.

NDIS Guide To Pricing Arrangements (2021-22)

The paper Item Item 20210513 - NDIS Guide to Pricing Arrangements, presented BY David Cullen Chief Economist, is noted BY The PRG INCLUDING: • rename NDIA Price GUIDE as the NDIS Pricing arrangements and price limits to reinforce PROVIDERS AND PARTICIPANTS that this document IS not a voluntary guide but sets boundaries within which registered providers must operate; • include definitive statements in the NDIS pricing arrangements & price limits: o the NDIA does NOT set prices charged by PROVIDERS, nor should they indicate these are set by them. o where provider charges differ for an NDIA participant compared with non-participant then ensure participants aware of difference. And o Providers should not impose conditions on Participants through Service Agreements unless aligned with those outlined IN the ndis pricing arrangement. Limits; • provide clarification when more than one worker can claim support delivery; • greater certainty for providers reducing administrative burden replacing blanket rule written permission from ndia pre-payments with nuanced approach.; • detail new requirements plan managers capture service providers’ ABN making payment requests even if NOT Registered.

NDIS SDA (Specialist Disability Accommodation) 2021-22

The paper Item Item 20210513 - item*, presented TO David Cullen Chief Economist, is noted BY The PRG INCLUDING: • rename SDI Price GUIDE as the SDA Pricing Arrangements and Price Limits to reinforce PROVIDERS AND PARTICIPANTS that this document IS a guide setting boundaries within which registered providers must operate; • increase SDA PRICE LIMITS & REFURBISHMENT THRESHOLDS July by 1 per cent in line WITH Consumer price index to March, 2021.

Next Meeting: JULY 2021 Date To Be Advised

Disclosure Log

Pricing Reference Group Meeting: May 13th - Minutes

Actions Arising

Meeting	Issues	Status
April 15^th, _²⁰²¹	Agency should provide any available reports from consultations participants regarding changes in Scheme.	Closed May/13/21/
May 13^th, _²⁰²¹	Consideration given including questions on self-insurance workers compensation new financial benchmarking survey. . . . _.	Open
MAY 13^TH, _²⁰²¹	Provide information to members about provision services autism through MBS and whether these other transitioned into NDIS.. . . _.	Open

Agency.

Insurance

Disability

National

Released information:

The act that was

Disclosure Log

Pricing Reference Group Meeting: August 6th, 2021 Minutes

The PRG INDICATED:

It considered workload considerable and queried its achievability in timeframe; suggested staggered approach might be more applicable. The Chief Economist agreed develop comprehensive schedule first six months alleviate these concerns.
Need NDIA work closely with participants participant advocates including developing better channels communication ensure needs met;
Supported need further education communicate help navigate Pricing Arrangements effectively;
Consider Chair’s statement meetings future could shorter frequent; Chief Economist outlined preliminary view next two meetings occur November February 2021, two meeting consider advocacy groups;
Role PRG Annual Price Review process add value independent voice give credibility decisions adding quality expertise; Next Meeting September October to December 3rd, 4am am

ACTIONS ARISING

Meeting	Issues	Status
May 9 May 2021	Consideration should include questions self-insurance workers compensation new financial benchmarking survey.	Open
5 May June July Augu 2021	Provide information members provision services autism through MBS whether transitioning NDIS.

Disclosure Log

Pricing Reference Group Meeting: November 09, 2021 Minutes

Date Tuesday ,November 09th Time :30 AM - PM Location Microsoft Teams Members Chair Gerrie General Manager Provider and Market Development Division By Teams Pricing Reference Group Members Deborah Julie Lynne Jim PSM Independent Member Independent Member Independent Member Independent Member Participating Observer nominated by CEO Lisa Sarah David Cullen Stephen Branch Manager DCEO Markets Governments Engagement Scheme Actuary Chief Economist Secretary Vincent Mardi A/g Director Project Assistant Price Regulation Unit Provider and Markets Division PRG NOTED The register of members’ interests.

PRG ENDEDORSED minutes of previous meeting PRG MINUTES OF MEETING August 6 th . The PRG noted that all open items are now closed Update by chair Consultants were appointed to facilitate Annual pricing review Financial Benchmarking Survey Increased activity regarding providers folding or putting themselves into voluntary administration For example Disability Services Australia who is one larger provider in New South Wales went into Voluntary Administration NDIA aware it not just bigger providers facing challenges but there number other providers raising financial issues

Disclosure Log

For Official Use Only

Meeting: September 5th, 2021

Minutes

A WA provider attempting their EB extinguished because it’s well above SCHADS Award awaiting Fair Work Commission ruling may have ripple effects sector other providers follow suit.

The NDIA was not setting prices enable inefficient businesses stay market.

The Scheme Actuary informed:

The NDIS Annual Financial Sustainability Report released same time provided Commonwealth Government October closely reviewed consultation States Territories including Disability Reform Ministers meeting subgroup senior officials working independent actuary Taylor s47F - perso modelling considered sound.
High levels concern raised projection total participant costs estimated $29 billion in , growing to $41 .4 billion and $593 billion to June 2025 increasing end June 2030.
Parliamentary Budget Office had similar projections scheme cost at an amount between $29-$30 billion for year ending March 2026.
Increased forward projections based on updated expectations number participants will reach of 859300 at end June 2030.

DCEO Markets Government Engagement PRG: NDS launched campaign economic value the scheme. This makes assumptions regarding benefits could be questioned.

Section: Annual Price Review (APR) 2021/2022

Paper PRG Update Pricing Item presented Chief Economist by economist. Chief Economist update progress APR financial Benchmarking Survey.

Appointed Consultant

Ernst Young EY were successfully appointed assist chief economist with annual pricing review.

Working Groups

The chief economist chair lead discussion these groups Ernst Young facilitate those groups assist writing papers chapters them each group attended from list providers there official working others involve State Territory representatives so additional groups meet three times two hours per meeting week every month.

Final Report

Reports individual working represent chapter final report annually priced review intended write report end March put forward to members early April then Board end April submissions received as November 2021 expectation spike submission closure date Novembe released under Freedom Information Act 1982 National Disability Insurance Agency.

Disclosure Log

Pricing Reference Group Meeting: November 09/25 Minutes

Financial Benchmarking Survey:

Appointed Consultant - Deloitte were successfully appointed to assist Chief Economist in financial benchmark survey.

Survey The survey will go live Nov-30/24 and providers notified via email Dec-16/27. An interactive seminar hosted by Deloitte Access Economics on Nov-25/27 assists with preparation and completion until Feb-04/28 fill out form.

Additional Survey There’s an additional benchmarking survey specifically plan managers support coordinators launching Jan-Feb/28 so real info about their constructions expected different from other providers.

The PRG DISCUSSED general matters regarding Annual Pricing Review:

Broad discussions collaboration co-design raised working groups, varying levels design based topic For instance reducing administrative complexity has higher elements improving experience for providers compared reviewing DSW cost model, PRG emphasised balanced view each group must be faithfully reflected Board decision sits board discussion consider PRG members attending some of these groups whether one two or more would appropriate DSS EY key NDIA members concerns timeline working groups benchmarking survey closing consultation paper May’22 considered tight but manageable., NDIA Private therapy dataset now includes data points large proportion private therapists don’t publish prices Of the that do there is often a difference price NDIS participants Next Meeting: Determined after meeting.

ANNUAL PRICING REVIEW

UPDATE TO THEPRICINGREFERENCEGROUP

01 February 2022

ANNUAL PRICING REVIEW

September 2021: Annual Pricing Review Terms of Reference released and Consultation Paper open for submissions
Over 400 submissions received

November 2021: First Meetings of Review Working Groups

400 Members Invited Across 12 Working Groups

FINANCIAL BENCHMARKING STUDY 2021-22

Deloitte Access Economics survey and analysis
- Survey open from November 28th through February fourth.
- Aimed to gather information on staffing numbers, costs, profits among support providers in NDIS (National Disability Insurance Scheme).
- Mandatory requirement for Temporary Transformation Payment claimants as per the National Disability Insurance Act 1982自由信息法。

As at January twenty-seventh: * Three hundred seven completed surveys, * Seven hundred fifty-nine additional surveys are ongoing,’ in progress’ * Reminders sent out both internally within DAE and externally via NDIA.

The initial phase of this study’s findings is scheduled around February twentieth-first. The aim behind these efforts includes increasing responses without requesting already known details; therefore, DAE has requested NDIA’s revenue along with participant data categorized under jurisdictional boundaries such as rurality alongside relevant registration groups.

PLAN MANAGEMENT AND SUPPORT COORDINATION BENCHMARKING STUDY

Disability Intermediaries Australia (DIA) undertook a national collection of information on the drivers and operating parameters from many plan managers and support coordinators, which closed in November 2021.
This was voluntarily done by DIA as there was no known national data set on the operational costs for Plan Managers and Support Coordinators.
803 unique submissions for drivers and operating costs for these supports for Financial Year 2020–21:
- Plan Management - Responses: redacted
- Support Coordination - Responses: redacted.
DIA provided a cleaned, de-identified dataset of survey responses to NDIA in January 2022.`
Provided to DAE for analysis, and comparison with Financial Benchmarking Survey.

DISCUSSION OF SUBMISSIONS AND WORKING GROUPS

OFFICIAL Page:503/1049

DSW COST MODEL AND PRICING ARRANGEMENTS

Common claims made by stakeholders across submissions include:

Concern about setting an effective provider at being among those with highest scores.
Provider argument: DSW level one salary base rates need adjustment upwards,
Supervisor span-of-control should focus per full-time equivalent rather than total staff count;
Overheads considered inadequate; this is a key factor in pricing arrangements but not surveyed explicitly yet.
Worker intensity seen as excessive without sufficient allowances for overtime pay or other benefits.
Lack consideration given towards paying taxes which could be significant barriers especially if it impacts profitability.

QUALITY AND SAFEGUARDING COSTS

Common claims made by stakeholders across submissions from attendees at WG4 include:

Claims about Cost Model not allowing increasing compliance burden (estimated as approximately ~!{5}% total costs). Audit costs are seen as challenging; estimated around $ {10} k annually. Providers also note an increase difficulty due to audit costs ($){5} hours time spent directly, said small providers face difficulties. Incident reporting has become more onerous: examples suggest one FTE per 100 in SIL client now needed. The Commission’s standard requires significant training, especially when dealing case clients needing a lot coordinated care and interaction between healthcare professionals; it feels that this isn’t sufficiently addressed within current model (CM). developing Clinical Governance Teams is necessary along with higher-cost professional staff. Claim CM Overheads need adjustment.

CORE GROUP SUPPORTS

DISCLOSURE LOG MR25/01967 FOI 24/25-2242 ndis

Common claims made by stakeholders across 39 submissions, including those from non-NDIA attendees attending WG5 include:

Submissions indicated that while improved transparency and accuracy were achieved through this pricing model, it came at an increased administrative burden.
Several costs are suggested will be incurred when implementing new pricing structures along with changes related to its billing process;
Providers reported facing decreased revenues due inability to recover expenses tied specifically towards non-facetoface interactions within these revised models;
Challenges noted during discussions involving interaction between plan administrators, as well as other key personnel involved directly or indirectly throughout such meetings.

TEMPORARY TRANSFORMATION PAYMENT

Common claims made by stakeholders across submissions (33) include:

Assists innovation.
Promotes capability building competition among NDIA attendees who are non-NDAIWG6 members. Providers asserted additional costs associated with being a registered provider within NDIS were temporary and diminishes over time.

THERAPY SUPPORTS

Common claims made by stakeholders across submissions include:

Current prices limit suggestions below standard market rates due limited workforce supply.
Inflationary indexation proposed annually instead currently when pricing reviewed).
Travel limits deemed insufficient; congestion issues in metropolitan areas not covering rural or remote settings adequately,
Price limits claimed inadequate rising training/supervising/upskilling costs such university students junior staffs.
Higher admin burdens reported on NDIS participants compared non-NDIS clients (e.g., reporting/compliance)
Lower utilizations therapists attributed increased administrative/reporting/administrative duties.
Suggested overheads were higher among therapy organizations.
High costs noted related therapist’s registrations/audits.

ABILITY FIRST’S PROPOSED THERAPY COST MODEL SUMMARY

Ability First Australia is estimated to represent 20% of the NDIS Therapy support market in 2020-21 financial year. • Suggested therapy costs: Psychologist = $226.43 per hour Other allied health = \$200.79 per hour Based upon a weighted average: Social worker (\$213.84) Speech pathologist(\$201.60). Occupational therapy( \ $)Occupationaltherapy($200.92). Physiotherapist ($193.79) • The primary drivers of hourly service provision cost are wages utilisation.The suggested difference was mainly driven higher base pay rate for psychologists(approximately, approximately approx.approx. 76%ofthe differencetheinperhour). • Service delivery regional and rural areas non psychology allied health services claimed be $10.10 more than metropolitan regions (attributedto time spent supervising training. • Points note: Parameters used based on group averages not efficient provider. From participating organisations highest proportion FTE servicing jurisdictions were WA (37.6%), NSW(23%)and SA (21.%)`.

NURSING SUPPORTS

DISCLOSURE LOG MR25/01967 FOI 24/25-2242 ndis

Common claims made by stakeholders, across five submissions and nine non-NDIA attendees to WG8:
- The minimum shift duration specified in nursing agreements must meet a standard requirement. The participant should receive compensation based on their actual working period rather than an arbitrary fixed amount per hour or day.
- There is dissatisfaction regarding nurses being compensated when they are unable to complete scheduled hours due to unforeseen circumstances (e.g., broken shifts). Poorly defined overtime pay policies also contribute significantly as these payments often cannot be accurately calculated according to agreed terms within existing frameworks;
- Concerns have been raised about cost indexing not having occurred over two years, implying that there has likely been inflation without corresponding adjustments for services provided under this framework;
- Travel budgets allocated specifically towards non-metro areas appear insufficient compared with those designated elsewhere.

PLAN MANAGEMENT

Common claims made by stakeholders across 23 submissions and 23 non-NDIA attendees to WG9 include:

Suggestions that when a participant moves from one Plan Manager halfway through their plan, the setup fee already paid is claimed by the initial Plan Manager. The subsequent Plan Manager cannot reclaim this cost due to lack of funding absorption occurs instead for set-up fees absorbed these costs.
Plan Managers report undertaking extra unpaid tasks besides invoice handling: including acting de facto as Support Coordinators during education sessions regarding fund usage within individual’s plans, or providing supplementary assistance needed by those with complex requirements, disadvantages, cultural backgrounds, linguistic diversity requiring more time.

DIA’S PROPOSED PLAN MANAGEMENT COST MODELS

Chapter 3.4 (from page 33) outlines the assumptions made for DIA’s proposed cost model for plan managers.
Proposed monthly price limit: $135.70 -$$74.93 cost per hour, multiplied by 1.48 average hours of support per month. -$$19.36 per month for setup costs (NDIA price limit / 12`) to change plan managers within plans with no loss in setup costs.

SUPPORT COORDINATION

Common claims made by stakeholders across 44 submissions and 28 non-NDIA attendees to WG10 include:

Submissions suggest providers are unclear about their scope role activities undertaken expectations service.
Claim there lack flexibility adapt changes circumstances crisis e g “a” participant dies).
There claimed that Level rare use compared others.
Raised concern in planning arrangements where believed level inappropriate highly complex participants.
Suggest added travel limits needed metro rural regio remotes area(s) .
Claims having higher overhead especially small orga nizations.
Claims having high admin burdens like resolvng agency errors or navigating redtape e g specific policies.)

DIA’S PROPOSED SUPPORT COORDINATION COST MODELS

Chapter 4.3 (from page 65) outlines the assumptions made for DIA’s proposed cost model for support coordinators.
Proposed hourly price limits:
- Level 1/Capacity Building and Training in Plan and Financial Management -$68.33
- Level 2-$110.04
- Level 3-$199.67

REGIONAL AND REMOTE SUPPORTS

Common claims made by stakeholders, across 31 submissions and 17 non-NDIA attendees to WG11 include:

Providers would like the Scheme to contribute towards accommodation costs for workers in remote areas, as they need to offer this to attract workers.
Best practice therapy is often to visit the participants in their natural environment, but travel costs are claimed not to be sufficient to cover this in remote areas.
Providers consider span of control ratios should be lower in remote areas, as supervisors often have to travel between workers.
Providers think allowance should be made for long travel distances for training.

QUEENSLAND, SOUTH AUSTRALIA AND WESTERN AUSTRALIA

Common claims made by stakeholders across submissions include:

Providers note that COVID border closures have made recruitment difficult.
WA & Qld face competition from high-wage sectors during mining booms, such as audits being driven upward for other services like housing scarcity due to reduced plan utilization among non-metro providers. Qld’s cost model limits allowed holiday days while South Australia recognizes half-days differently than most states.

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ANNUAL PRICING REVIEW

Early February 2022: Second meetings of Review Working Groups
Late February/Early March 2022: Third meetings of Review Working Groups
April 2022: Announce results of Annual Pricing Review
June 2022: Release final price limits

Disclosure Log

Pricing Reference Group Meeting: February 01/25-2422

Minutes Document 50

For Official Use Only

Date Tuesday, January 31st, Time: AM - PM Location Microsoft Teams Members Chair Gerrie General Manager Provider and Market Development Division By Teams

Pricing Reference Group Members Deborah Julie Lynne Jim Graeme Independent Member Independent Member Independent Member PSM AM Independent Member By Teams

No Apologies Participating Observer nominated by CEO Lisa DCEO Markets Governments Engagement David Gifford A/g Scheme Actuary David Cullen Chief Economist Tanuja A/g Branch Manager Pricing Stephen Branch Manager Provider Engagement Secretariat Vincent A/g Director Pricing Operations Price Regulation Unit Mardi Project Assistant Pricing Operations Price Regulation Unit Declaration of Conflicts Interest The PRG NOTED the register of members’ interests.

Lynn declared that she is Chair of the Liver Foundation.* Confirmation of Previous Meeting’s Minutes The PRG ENDEDORSED minutes from November meeting: PRG Minutes of Meeting 9th November 2021. All open items are now closed.

Disclosure Log

FOR OFFICIAL USE ONLY

Pricing Reference Group Meeting: 1 February 2022 Minutes

Four new members have been appointed to the NDIA Board, effective January 1st. Jim will serve until permanent appointment made (s47F - personal).
The external environment for disability sectors changes due COVID-19; increased focus aged care & health services resources pressure wage people resources.
Department Social Services continues engaging states territories various matters including path deregulation overarching pricing framework.

Update Annual Pricing Review

The Chief Economist presented: o Over(provider) submissions received summary documents sent PRG Members those(submissions).o Held first round working groups providers other stakeholders second round meeting commence February Summary document(first)(round(working(groups))have(sent(PRGMembers)). o Agency findings provided Board around March April Decisions recommendations subsequent announcement follow.

Financial Benchmarking Study

Pricing Branch Manager presented: o Survey administered and analyzed Deloitte Access Economics track receive similar number responses last year.o Overall survey response rate approx.(provider claiming Temporary Transformation Payment(TTP))(approx.)% of.providers(o TTP) o Agency receives dataset from Deloitte Access Economics analysis by agency. o PRG asked about(response rate compliance obligations associated with claim Temporar(yTransformationPayment).

Plan Management Support Coordination Benchmarking Study

Pricing Branch Manager presented: o Surveys Disability Intermediaries Australia(DIA)received 803, plan managers support coordinators respectively. o DIA argues should price rise they provide deidentified data set survey responses to theAgency where analysis concentrated on efficient average provider substitution leads prices too high (cost model). o PRG discussed analysis efficient going forward if continuing setting limits at percentile potentially reduce market supply long term. PRG –20220201–Minutes Page520of1049

DISCLOSURE LOG

FOR OFFICIAL USE ONLY Pricing Reference Group Meeting: February 1st , Year 2022 | Minutes

Discussion on Submissions & Working Groups

WG-03 - DSW Cost Model And Pricing Arrangements

PRG requires further clarity regarding overheads potentially setting these costs somewhere between median or at least up until percentile.
Discussed payroll tax issues where some pay it while others do not, leading significant efficiency differences impacting both profit/non-profit sectors which may drive inefficiencies into sector overall.

WG-04 Quality Safeguarding Costs

Potential cost impacts for registered vs unregistered providers with compliance and safeguarding costs; proportion used to measure impact over time is discussed but evidence lacking about provider conversations around bundled supports needed culture change.

Core Group Supports (WG)

Suggested menu contracts demonstrating bundle services compared bespoke support delivery; however there’s little evidence that providers are having conversation participants about potential bundles.

Temporary Transformation Payment TTP (TG)

Briefly touched non-compliance survey addressed in point Financial Benchmark Study update;
General misconception amongst providers of purpose behind TTP noted by Agency. Clearly stated economic position was TTP did represent efficient rate supporting inefficient providers until their structures became more effective generally think TTP covers existing costs rather than being transformative payment mechanism.
Recent initiatives like COVID allowing NDIS funds outside participant plans as direct payments to providers could be alternative approach changing behavior.
Innovation incentivized within government funded schemes worth investigating.

Therapy Support (Wg7)

PRG heard feedback therapy providers want price increase since last indexed July 2020.

DISCLOSURE LOG

FOR OFFICIAL USE ONLY Pricing Reference Group | Meeting: February 1, 2022 | Minutes

Chief Economist presented results from a dataset showing therapy prices advertised online (8k) vs non-NDIS rates. The subset includes weekday data (€4K), room-based services, travel fees etc., split into WA/QLD & VIC-SA regions using new models. wg08 - Nursing Supports:

Approximately €37-€6 million spent annually on nurses; five nursing items capture varying skill levels complexity.
Significant uncertainty due to pandemic impact public health system supply issues for nurses entering NDIS scheme. wg09 Plan Management:
PRG discussed concerns about distinguishing between plan management/support coordination and overlapping advice provided participants. Both groups want price limit adjustments but face double-counting dilemma regarding cost/service provider roles/functions. When NDIA’s proposed Point-of-Sale is implemented it will affect role functions of PMSC space. dia submission suggested ceasing customer acquisition fee setup costs instead building them in monthly fee. wg10 Support Coordination:
DIA modeling shows low utilization high overheads; Level III rates at par with therapy rate ($194). could consider support coordinators after participant death. The National Disability Insurance Scheme Act 2013 has provisions for deceased participants, where plans cease upon that event. policy prohibits billing the plan by managers or coordinators when providing service. wg11 Regional Remote Supports Significant parts regional Australia are isolated current travel rules inadequate meet demand areas. note planning practices do not account旅行费用 during planning stage, may need review for remote regions allowing off-plan allowance providers servicing those locations may benefit from this approach. support coordinators can assist linking participants/providers reducing expenditure on schemes focus placed forward.

DISCLOSURE LOG

Pricing Reference Group Meeting: February 03/24/5222 Minutes

WG12/13/14 – QLD SA WA

The PRG heard that Western Australia’s mining boom would likely affect its disability worker market; however border closures have limited bringing in workers from other states and overseas.

Next Meeting:

Thursday March 7/2022 at 6pm

ACTIONS ARISING

#	Meeting	Issues	Status
1	`Meeting`	Notify members when DSS releases public consultation on Scheme pricing framework.	Open
2	`Meeting`	Share Deloitte Access Economics Financial Benchmarking Survey analysis with members.	Open
3	`Meeting`	Payroll tax paper to be circulated before next meeting.	Open
4	`Meeting`	Presentation slides for therapy prices shared with members attached file.	Attached File
5	`Meeting`	APR used during last meeting shared as attachment.	Attached File
6	`Meeting`	Analysis of proportion registered vs non-registers over time open status.	Open
7*******	`Meeting`	Follow up details government schemes allowance or incentive innovation.	Open

ANNUAL PRICING REVIEW

UPDATE TO THEPRICINGREFERENCEGROUP

03 March 2022

Updates by the Chair

Disclosure Log

Discussion of draft chapters

This document was released under the Freedom of Information Act 1982 by the National Disability Insurance Agency.

Plan Management consultation

Common claims made by stakeholders across submissions and non NDIA attendees include:

Suggestions that when participant moves halfway through their plan set up fee has already been claimed initial PM no funding new PM absorbs these costs. Plan Managers also claim additional unfunded work beyond processing invoices These activities include: Acting defacto Support Coordinator participant requires educating or enquiries about funds in plans Providing support complex needs disadvantaged CALD participants which require hours DIA’s Cost Model proposal Proposed monthly price limit $13570 $ cost per hour multiplied average hours month. support per month. costs (NDIA divided months) for changing without loss setup costs.

Plan Management preliminary findings

In 2020–21, more than half (51.8%) of all active participants (*participants who made a claim from their plan in 2020-21) used a Plan Manager for some or all of their plan.
The number of Plan Managers continue to grow.plan management providers commenced operationsin 2020−21 and129 plan management providers commence operationss inthe first two quartersof2021−22*. The results of Disability Intermediaries Australia’s survey show thata significantnumberproviderares making healthy return ontheir investmentunder current NDIS price limits—with46%PlanManagers achieving an EBITDA aboveabove**10%. *There is lackuptakeon Capacity Buildingand TrainingIn Plan FinancialManagementby support item.A PlanManagerOf 258,981 participantwho madeclaimfor amanagementitemonly (0.) did make this claim.

Plan Management draft recommendations

The Review proposes:

That the Agency should simplify the pricing arrangements for plan management supports from July 01/2023 by:

Replacing current monthly fee and establishment fee arrangements into a single monthly fee arrangement which amortises support item.
Decommissioning Capacity Building Training in Plan Financial Management Support Item broadening scope core support item 01_134 to capacity building training self-management-plan management.
Price limits index each year (commencing) using PI-X approach labour supports.
Ensure that Plan Managers have complete access all parts relate components participant appointed them manage relevant information intent on.

Plan Management draft recommendations continued

The Review proposes:

That the Agency should publish a clear statement of the respective responsibilities of participants, providers and Plan Managers with respect to ensuring that Scheme funds are only spent on supports that are reasonable and necessary and in accordance with the intent of the plan.
That the Agency should allow Plan Managers to bill the agreed monthly plan management fee for up to three months after a participant’s death – so that they can finalise the participant’s outstanding invoices etc..
That the Agency should establish a working group to further examine and address any issues in the current pricing arrangements that inhibit the uptake of shared management arrangements.
That the Agency should explore options to ensure longer plans, can be rolled over appropriately account for material changes price limits have occurred or might occur during duration

Quality and Safety costs (QSC)

The Quality and Safety Commission is responsible for setting and enforcing safety and quality standards.

The Agency needs to ensure costs of complying are covered in the Cost Model. (This does not necessarily include the costs of non-compliance)

QSC consultation

Common claims made by stakeholders across submissions and non-NDAI attendees include:

Claims that NDIS disability support worker DSW Cost Model does not allow increasing Commission compliance burden estimated ~5% total costs audit costs said difficult small providers $10k p.a direct costs $50 hours time cost - Providers report incident reporting getting more onerous examples FTE per SIL clients now required Suggest Commission standards require substantial training complex client coordination with health professionals feel neither covered adequately in model Claim there need develop clinical governance teams high cost health professional claim overheads should be increased

Growth in QSC compliance costs

Preliminary findings:
- While the idea was that one national uniform set of safety regulations should reduce compliance costs, near universal feedback is that the opposite has happened.
- A number of providers report compliance costs had increased by orders of magnitude.
- The Review estimates that compliance costs have increased by 0.75% of total costs since the introduction of the Commission in 2019.
- Many providers stated that more time was required for supervision and training to meet increasing safety regulation.
- However, the financial benchmarking survey indicates that utilisation is not decreasing for either DSWs or front line supervisors (FLS)

Impact of QSC compliance costs

Stakeholder feedback:
- Several submissions indicated that smaller providers – especially sole practitioner therapists - were not able to cover the costs of QSC registration.
- Assistance with Daily Living (ADL) providers complained that it was not fair that unregistered providers did not have to face the same compliance costs and wanted DSW Cost Model differentiate between registered an unregistered providers.
- Some providers suggested number practice standards excessive They noted national Standards disability Services had six standard quality indicators but some now faced sixty two standards twenty nine seven quality indicator. However while cost Commission regulations is within purview Review efficacy such regulation isn’t.

QSC draft recommendations

The Review proposes:

That the Agency should increase the price limits of core supports to recognise the increased costs that providers face in ensuring that they deliver are high quality and safe. This should be done younging the overheads loading inthe NDIS DSW Cost Model from (\text{from}~{}^{13}%).
To recommend different prices registered unregistered providers.
Not recommended reducing utilisation levels model safeguarding compliance hours.

Nursing support consultation

Common claims made by stakeholders across submissions and non NDIA attendees include:

Minimum shift duration: Two hours; participants can be billed based solely upon their time worked.
Nurses must receive compensation when shifts are broken or extended beyond scheduled times which cannot currently be claimed through NDIS funding mechanisms;
Concerns regarding cost indexing that has remained stagnant over a two-year period,
Travel budgets deemed insufficiently allocated especially in rural areas.

Nursing supports - preliminary findings

In 2020–21, 14{comma}997 agency-managed and plan-managed participants received NDIS funded nursing supports (3\%.**4%***of all participants who made a claim for one or more supports in *2020-21*) •In total,the Scheme expended `$85.8 million$on nusing supporstsin $2020-$21. •Most nursingsupports were deliveredby Registered Nurses (68 %.**3%****b y valueo fsupport)and EnrolledNurses(19 .O%). •The currentNDIS price limitsfor nurssing supportsd o not allow providers to pay competitive nurses wages withthepublicsystem, this has becomemore acute during th eCOVIDpandemic, •Employment statistics confirm that there is currentlya high demand fornurses across Australia. •Current NDIs definitions of time od day(Evening an dNight shifts)d onot alignwith then shiftdefinitionsinthenurisngAward.

Nursing supports draft recommendations

The Review proposes:

The price limits for nursing supports delivered by enrolled nurses and registered nurses should be significantly increased (by 27.1% and 25.5%, respectively for weekday services). It also proposes similar increases for other types of nurses and other shifts.
The price limits for nursing supports should be indexed on July each year using the PI-X approach for labour supports starting from June .
That the Agency should align shift definitions with those set out in Nurses Award 2020,
that the Agency should amend level to provide greater clarity providers,
that considers that nursing providers should able claim time nurse spends travelling if certain conditions met.

Temporary Transformation Payment (TTP)

Registered providers have access to higher price limits.
Eligibility conditions are publish service prices; list contact details in Provider
Participate annually in financial benchmarking survey
Currently 4.5% Scheduled to reduce to 3% on July 07 2022
For following registration groups:
- High Intensity Daily Personal Activities (0104
- Daily Personal Activities(0107)
- Participation In Community Social and Activities(0125) `
- Specialised Supported Employment (0133)
- Group And Centre Based Activities(0136)

TTP consultation

Common claims made by stakeholders across submissions and non-NDAI attendees include:

Assists innovation promotes capability building competition.
Providers asserted that additional costs associated being registered provider in NDIS were temporary diminishing over time.
Providers suggested current underutilisation support items due barriers accessing claiming TTP includes:
- Administrative burden cost applying claiming TTP .
- High complexity explaining participants as well as claiming TTP.
- Additional funding participant plans available TP is not.
Concerns providers advising participants use TTP because plans increased.

Future of the TTP

Stakeholder feedback:
- A number of submissions argued that the TTP has been successful in promoting efficiency – and thus should be retained.
- Some providers felt there would value maintaining TP recognition increasing difference compliance costs faced between registered unregistered providers.
- The Working Group considered replacing with higher set base prices which recognise ongoing nature agency Commission compliance costs.
- There now stronger evidence average cost service delivery at or below current price limit.

TTP usage in 2020–21

18.4 million TTP-eligible supports claimed.
Worth $7 billion.
Delivered by 62,219 registered and unregistered providers to €198‿298 participants (▲45%) Scheme participants).
(52% ext{of claims}forTTP-eligiblesupportswerefortaTTPitem)
(43%) expenditure on TTP eligible-supportswason TTPItems

TTP usage in 2021–22

Only 47% of claims for TTP-eligible supports were for TTP items.
Only 38% of expenditure on TTP-eligible supports are spent on TTP items. • TTP items account for:
- 29% of expenditure on TTP-eligible supports within Assistance with Daily Life; • 47% of expenditure on TTP-eligible supports towards Community Participation
- 65% of expenditure is allocated toward Employment Supports, • $‘70m’ has been expended during H1/2021.

TTP compliance

Only 64% of providers who claimed the TTP in 2020-21 completed the financial benchmarking survey.
Conversely,** redacted: s37 - law enforcement and public safety:*** redacted of registered providers who could have - but didn't - claim the TTP in *2020-21* voluntarily agreed to take part in the survey.

TTP draft recommendations

The Review proposes:

That the Agency should cease the TTP from July 01/25-24.
That the Agency should partner with the sector to:
- sponsor annual financial benchmarking survey; and
- address information asymmetries facing participants publishing localised prices specific supports.

NDIA Financial Benchmarking Survey

preliminary results

NDIA Financial Benchmarking Survey

Preliminary Results - Base rate of pay

Agency.

Insurance

Disability

National

information

freedom

####### act ######## release

NDIA Financial Benchmarking Survey 2020–21 Preliminary Results – Workforce

Parameter	Mean	Median	`75 PC`	DSW CM
Permanent employment rate (%)	60.02	63.83	28.69	94.51

NDIA Financial Benchmarking Survey

Preliminary Results - Salary On-costs

NDIA Financial Benchmarking Survey

Preliminary Results - Standard hours of work and Leave

| Parameter | Mean | Median | 75 PC | DSW CM | |-|-|-|-| | Hours per day (hrs) | 7.46 | 7.60 | **7.**50 | 7.60 | | Annual leave (hrs) | _163.59 | 1.5____2.****0_________| 1_____________________5_______________________.| 1__________________________________________________________________________||

NDIA Financial Benchmarking Survey

Preliminary Results - DSW Utilisation

| Parameter | Mean | Median | redacted PC | - redacted-PC | DSW CM | |-:|–:-:–:––:—–:——: | Total utilisation (%) | 8234 | 8500 | 9200 | 7500 | 92 (A), 89(B) ,

 		   87(C), `€€`	(D)|

| Billable time (exc. travel)(%) | **77**,23 | *80* 00 | *90* 00 | * 70* 00 | N/A | | Non billable client-related administration %` | **4,**17 | 3.00 | *5.*00 | .00 .00 | N/A |

NDIA Financial Benchmarking Survey

Preliminary Results - FLS Utilisation

NDIA Financial Benchmarking Survey

Preliminary Results – Overheads and Profits

| Parameter | Mean | Median | 25 PC | 75 PC | DSW CM | |-|-|-|-|-| |Overhead % loading direct costs |43.83%||2162 || |Excluding interest depreciation overheads as share cost |30.4726.3717.78***36.01*****10.71 |EBITDA total costs margin = 2.00|

NEXT STEPS

Page 555 of 1049

Review of Pricing Arrangements for Supported Independent Living

Disclosure Log

Document: DOCUMENT-45

For Official Use Only

Matter for Decision - Review of Pricing Arrangements for Supported Independent Living Prepared By David Cullen Chief Economist

Purpose:

Recommendations (PRG recommends through CEO):

Background & Supports within NDIS:

DISCLOSURE LOG

Exhibit 30: Efficient Costs in SIL and Non-SIL Settings

5. Discussion – Recommendation 2.2

Disclosure Log

FOR OFFICIAL USE ONLY

Pricing Reference Group | Date: April 15th , Year : 2020 | Item Number: item-3-dot-2

Further,

The review acknowledges vacancies present issues but not necessarily deficiencies within unit price limits; instead it points out planning arrangement inadequacies which don’t always adjust participant plans based on vacancy changes;

Next Steps

Price Regulation Unit tasked working alongside other Agency areas implementing recommendations including guidance participants/providers/partners and staff alike.

Recommendations are set forth July first year:‘2021’, published four weeks prior implementation date.

Risks

Disclosure Log

For Official Use Only

Pricing Reference Group | Item 3.2

Disclosure Log

Document: NDIS Review Report - April 2021

Title:

Disclosure Log

Copyright

Use of National Disability Insurance Agency copyright material

Terms that we use

Disclosure Log

Contents

Introduction…7

Context……7

Conduct of the Review…..11

Methodology…….12

Findings…………16

Wages and On-costs………16

Workforce mix……….22

Utilisation……………25

Supervision costs……..30

Overheads…………….40

Supply Costs Specific To SIL Services..35

Conclusions………..40

Disclosure Log

List of Exhibits

Executive Summary

Disclosure Log

Review of Pricing Arrangements for Supported Independent Living

Disclosure Log

Introduction

Disclosure Log

Review of Pricing Arrangements for Supported Independent Living

Average Annualised Plan Budgets, September *

Disclosure Log

Review of Pricing Arrangements for Supported Independent Living

Exhibit 2: Average Annualised Payments, 2019–20

NDIS Pricing Arrangements and the Disability Support Worker Cost Model

Page footer

Disclosure Log

Exhibit 3: Schematic overview – NDIS Disability Support Worker Cost Model

Conduct of the Review

Issues Papers and Submissions

Consultations With Peak Bodies

Disclosure Log

Review of Pricing Arrangements for Supported Independent Living

Consultations with Other Schemes

Desktop Research

Disclosure Log

Review of Pricing Arrangements for Supported Independent Living

The 2019–20 Financial Benchmarking Survey Data

Disclosure Log

Review of Pricing Arrangements for Supported Independent Living

Differences between SIL and non-SIL providers in the survey

Disclosure Log

Review of Pricing Arrangements for Supported Independent Living

Statistical Analysis of 2019-20 Financial Benchmarking Survey

Findings

Disclosure Log

Review of Pricing Arrangements for Supported Independent Living

| Respondent type | Sample size | Mean (%) | Median % | `75th` percentile% | |-|-|-|-| | All respondents | 698 | 79.4 | 80 | 70. - 90. | | Non-SIL respondents | 495 | 77.9 | 80 | 70.- 88. | | Mixed (SIL/ADL) respondents | 203 | 82.7 | 84 |- * incomplete data*

Exhibit Regression Analysis – Staff Utilisation Rate^**

| Regressor | Mean (%) | Median % | |-|-| | `SIL` indicator variable | 0.04 - 0.26* |- * incomplete data*

Exhibit 29: Regression Analysis – Overhead Costs²⁰