Disclosure Log

The contents of this document are OFFICIAL.

National Disability Insurance Agency

Pricing Reference Group Meeting Agenda

Date: Thursday April 21st Time:* from 10am to 3pm Meeting: Videoconference using Microsoft Teams (Refer meeting invitation for details)

Members

Pricing Reference Group Members

Participating Observer nominated by CEO Lisa DCEO Markets Government and Engage Group |By Teams|

Time	Item & Topic	Presenter/s	Matter for Format

Disclosure Log

Pricing Reference Group (PRG)

Meeting: 29 March 2022

Minutes

Date: Tuesday, 29 March 2022 Time: 11.00am – 12.00pm Location: Microsoft Teams

Members

Chair: Gerrie s47F - persona General Manager, Provider and Markets Division By Teams

Pricing Reference Group Members:

deborah s47F - person Independent Member By Teams julie s47F - personal privacy, s2 PSMIndependentMemberByTeams lynne s47F - personal priva Independent Member By Teams jim s47F - pePSMIndependent Member By Teams graeme s47F - personIndependent Member By Teams

Participating Observer nominated by CEO Lisa s47F - personalprivacy DCEO, Markets, Governmentand EngagementGroup By Teams David Gifford A/g Deputy Scheme Actuary By Teams Tanuja s47F - persoA/g BranchManager,Pricing By TeamsDavid Cullen ChiefEconomist By Teamss Stephens47F-personalprivacys2BranchManag erProviderEngagement By Teams

Secretariat Vincent S47Fpersonalpr AGDirectorPric ingOperations By Teams Jodie Snr Engagem ent OfficerProv iderEn gage mentBran ch By Teams ScottS47FPerson al Priv a DirectorAnnualPriceReviewTeam By Teams Dominic S 47 FpersonAGAssistantD irectorAn nualPri ceRe viewTe am By Teams

Declaration of Conflictsof Interest The Chair ASKED members if they had any updates on conflicts off interest to declare PRGmembers did not haveanyupdates.

ConfirmationOfThePreviousMeeting’sMinutes:

ThePRGEDORSED the minutes fromthe previous meeting: PRGMinutes Meeting3March This document was released under

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Update by the Chair

The Chair INFORMED the PRG:

That Minister Reynolds had recently announced the appointment of Dr Denis Napthine AO as Chair of the NDIA Board.
About the approach NDIA would take to seek the NDIA Board’s agreement of Annual Pricing Review (APR) recommendations. PRG members offered their assistance in briefing the NDIA Board.

Core Supports – Disability Support Worker (DSW) Cost Model

The Acting Branch Manager of Pricing referred to the paper circulated on the DSW Cost model and spoke to the findings and recommendations.* The PRG DISCUSS EDtheD SWCostModelpaperincluding:• Suggestions for additional detail to justify the proposed cost model; clarification about timingandimplicationsofFairWorkCommissionannouncements.•PricingarrangementsforGSTregisteredandoneregisteredprovidershowotherschemesapproachthis,andlikely implicationsforthefor-profitandenot-for-profits providers.TheChair/PRGNOTEDthattherewouldbefurtherclarificationontheproposedpricelimitchanges.

High Intensity Supports*

TheChiefEconomistreferredtothepapercirculatedHighIntensit ySupportsandspokeinthefindingsandrecom mendations.* The PRGDISCUSSEDHig hIntensitySuppor ts pap er including:

Benefitsofconsistencyindefinition sand likelyim plications fors upportworkersan dparticipants.-The needtomonitorthemarketinalighto fany changesintore sponse t o th e prop os ed arrangement .Group-basedCoreSupports* ThActingBranchManagerOfPr ic ingrefere dt ot hepapercirc ulate don Group -based Core Suppo rts an dspeaktothefindingands recom m enda tion s. The P R GDISCUSSE Dt heG roup-b as edC oreS upp ort sp ap ep,including:•Maincontributingfactorstolownumber of providersthathavetransitione dtothenewpricingarrangements •How the NDIA could simplify transition process , inclu dinginteractionsbetweenthisandother recommendationsforbilling •Importanceoftainingparticipant-centric principles •NDI A’s proposed intensiveprovidercommunications/educationpiece,andhowtheN DI Acoulddemonstratebestpracticefromthedifferentmodelsalready introducedaspartofprovidereducation.

Therapy Supports*

TheChiefEconomistreferredtothepapercirculatedonT herapySu pp orts andspoke totheadfindings andrecom mendations.* The PRGDISCUSSED T h er a pySuppor ts pap erncluding:

How NDIAs pricing arrangements aligned with thoseofotherpublic schemes

Disclosure Log

the extent to which NDIS therapy support providers required additional or specialised skills compared with therapists more broadly; where such providers may require extra hours.
Arrangements in this sector are tailored for people with disabilities but there’s scope to explore mainstream options;
Consistency between pricing arrangements is crucial when comparing supports like nursing versus Allied Health therapies.

Disclosure Log

The contents of this document are OFFICIAL.

National Disability Insurance Scheme Annual Pricing Review 2021–22 DRAFT Report on Consultations April 2022

Delivered by: ndis National Disability Insurance Agency

DISCLOSURE LOG

OFFICIAL

Copyright

©️ 2023 Copyright ownership and protection: The copyright in information contained within documents belongs exclusively to the National Disability Scheme Launch Transition Agency.

Use Of National Disability Insurance Agency Material

The material herein has been licensed according Creative Commons CC NC license version 4. Under specified exceptions such logos or trademarks; third-party materials are excluded from reproduction rights except as noted below:

Reproduction permitted with acknowledgment stating ‘National Disability Insurance Agency’ owns all intellectual property associated;
Acknowledgment must be included using © National Disability Scheme Launch Transition Agency followed year (e.g., “2025”) unless otherwise stated, ensuring non-commercial use is maintained throughout publication.

Disclosure Log

OFFICIAL

Introduction…5

Terms of Reference of the Review …5

Consultation Paper ….7

Working Groups….7

Core Pricing Arrangements …..9

####### Pricing Strategy ….. ######## Key Parameters of the Cost Model….. ############ Fair Work Commission’s yearly review of SCHADS Award 2010.. ################ Claiming Rules. ######################## Planning and other Issues..

Group Based Core Supports……35

####### Value of Group Based Programs……..35 ####### Pros and Cons of New Transitional Pricing Arrangements…….35 ####### Costs delivering group-based supports ……..40 ####### Program Support……….41 ####### Capital Other costs………43 ####### Options for change ……….44

Temporary Transformation Payment ……48

####### Support TTP…………….48 ####### Barriers to accessing claiming TTP……………50 ####### Future of The TTP …………….53

Quality Safeguarding Costs ……..57

####### Provider registration ongoing compliance audits……..57 ####### Practice standards……..61 ####### Incident restrictive practice reporting……..65 ####### Training Professional Development……..68 ####### Supervision……..70 ####### Other issues……..72

Therapy Supports .72

Pricing Arrangements…72

MR25/01967 FOI 24/25-2242

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OFFICIAL

Introduction

This document summarises the evidence that was provided to the Agency through extensive consultations with participants providers and other stakeholders undertaken part Annual Pricing Review. The views expressed in are those Agency We have produced report provide summary feedback received during these consultation will be published separately Report 2021-22 Annual Pricing Review The Agency’s response issues raised consults will be published separately Report 2021-22 Annual Pricing Review .

Terms Reference review were established Board They required Agency examine engagement participants community government stakeholder targeted research whether Scheme existing price control framework (pricing arrangements limits) continues appropriate or should modified In particular agency required:

Examine options simplify where possible NDIS price control framework better support participants exercise choice reduce regulatory burden pricing arrangements impose on participants provider * Review core supports, methodology parameters used Cost Model Disability Support Worker including analysis most recent financial benchmarking data paying regard Fair Work Commission yearly review modern awards Social Community Home Care Services Award 2010 AM ;
Identify any unintended consequences new group-based participation supports introduced July impact overhead costs administrative complexity for providers participant;and
Examining extent Temporary Transformation Payment achieved their purpose continue value money.\footnote{The decision by can found here}

DISCLOSURE LOG

Review the pricing arrangements for therapy and nursing supports, including whether NDIS pricing arrangements are appropriately aligned with those in comparable Australian Government and state schemes, and with the private market for therapy supports,
- Examining the nature of the markets for therapy and nursing services, including extent to which these markets consist distinct segments such thin undersupplied regions remote areas;
- Undertaking detailed benchmarking against both relevant comparable government scheme mainstream markets;
- Examing competition within regional service.
Review support coordination plan management encourage innovation improve quality ensure value money .
Review that apply to supports delivered regionally remote very remote areas continue access appropriate participants living there area.
In line Recommendation Market Review economic conditions states where trends counter cyclical other states territories (and particularly Western Australia Queensland South Australia) require temporary adjustments price controls order manage potential impacts supply disability goods/services. In framing its recommendations Agency cognisant objects principles set National Disability Insurance Scheme Act 2013 include: Support independence social participation people disability ; Enable exercise choice control pursuit goals planning delivery their supports Facilitate development nationally consistent approach accessing funding supports people disability Promote provision high-quality innovative supports enable maximize independent lifestyles full inclusion community Adopt insurance based approach informed actuarial analysis provide fundings supports people disability financially sustainable.

Disclosure Log

Official Introduction

Consultation Paper

On October 14th, 2021, A Consultation Paper was published in support stakeholders preparing submissions Annual Pricing Review Submissions were due Sunday November but some received after date total submitted are listed Appendix Most from provider organisations and individual therapists or support workers/providers . Submissions also came participants their representatives participant representative organizations agency engaging with options simplify pricing arrangements empower consumers through Participant Reference Group other channels. The most addressed topics Therapy Core Pricing Arrangements Support Coordination Plan Management The Agency grateful all individuals organisms took time make submission has carefully considered all submissions.

Working Groups Twelve stakeholder working groups established:

Working Group (Core Pricing Arrangements): To assist examine design key parameters use NDIS Disability Worker Cost Model set price limits Scheme particular concern implications cost model for outcomes Fair Work Commission’s yearly review modern awards Social Community Home Care Disabl Services Award AM This group tasked reviewing general pricing arrangements including rules governing billing non-face-to-face supports travel cancellations).
Working Group Quality Safeguard Costs: Assist to examine costs of registering NDIS Quality Safeguards Commission associated ensuring quality safety disability appropriately accounted prices core capacity building supports)
Group Pricing Arrangements For Core Supports): Identify any unintended consequences new pricing community participation supports introduced July impact overhead administrative complexity providers participants
Temporary Transformation Payment arrangement examined extent achieved purpose continue provide value money.) Therapy Supports) was assisted examining competition market therapy supports improve effectiveness efficiency those supports.“

DISCLOSURE LOG

Working Group 6 (Nursing Supports) was established to assist the Agency to examine the extent of competition in the market for nursing supports and options to improve the effectiveness and efficiency of those supports.
Working Group 7 (Plan Management) was established to assist the Agency to examine the costs of delivering plan management supports and the appropriate pricing arrangements for those supports.
Working Group 8 (Support Coordination) was established to assist the Agency to examine the costs of delivering support coordination and the appropriate pricing arrangements for those supports.
Working Group 9 (Regional and Remote Supports) was established to assist the Agency to examine the costs of delivering supports in regional and remote areas, and arrangements to ensure access to supports for participants living in those areas.
Working Group 10 (Queensland) was established to assist the Agency to examine the costs of delivering supports in Queensland relative to other states and territories.
Working Group 11 (South Australia) was established to assist the Agency to examine the costs of delivering supports in South Australia relative to other states and territories.
Working Group 12 (Western Australia) was established to assist the Agency to examine the costs of delivering supports in Western Australia relative to other states and territories. Some individuals from organisations participated in working groups see Appendix B). The working groups each met by videoconference on several occasions between November March .

Working Group	Second Meeting	Third Meeting
Core Pricing Arrangements	30 Nov Feb Mar
Quality Safeguarding Costs	Feb Mar	`
edacted s47A - business operations`:`
edacted: s46 - contempt court`, etc.)
Group Supports	Mar
Temporary Transformation Payment
Therapy Supports	Feb Mar	`
edacted s45 - material obtained confidence`:`
edacted: `etc.`)
Nursing Supports	Feb Mar	`
edacted s48 - secrecy provisions`:`
edacted: `etc)`
Plan Management	Feb Mar	`
edacted s49B - Commonwealth-State relations`:`
edacted: `etc`) Support Coordination	Feb Mar	`
edacted s49C - deliberative processes`:`
edacted:` etc.
Regional Remote Supports	Feb Mar	`
edacted s49D - financial property interests of the Commonwealth`:`
edacted:` etc. Queensland	Feb Mar	`
edacted s49E - certain operations agencies`:`
edacted:` etc South Australia	Feb Mar	`
edacted s49F - personal privacy`:`
edacted:` etc Western Australia	Feb Mar	`
edacted s49G - third party affairs`:`
edacted:` etc
The Agency is grateful to all individuals and organisations who brought their considerable experience expertise Working Groups.

Core Pricing Arrangements

This chapter reports on consultations held between participants and stakeholders regarding ongoing appropriateness methodology parameters used in NDIS Cost Model Disablity Support Worker paying particular regard outcomes Fair Work Commission’s yearly review modern awards Social Community Home Care &Disability Services Award AM . It also reports consultation Scheme’s general pricing arrangements. Total submissions Consultation Paper provided Appendix A working group providers other stakeholder established had members organisations met video-conference occasions December February February Details Working Group Provided B key topics raised were: Pricing Strategy; Key Parameters Cost Model; Fair Work Commision’s year review SCHADS Award ; Claiming Rules Other Issues.

Pricing Strategy

A number submisions indicated principal assumption current pricing arrangement use percentile provider performance inappropriate These submission argued unreasonable assume providers achieve efficiency level across all aspects different client complexities support types Submission Tulgeen example argued should reconsidered current approach not environment gives any degree comfort to particpants services they receive can maintained Empowered Futures similarly stated model prices set at 25th percentile is blatantly needs-based model The pricing assumed lowest price of support delivery stagnant view supports needs.

DISCLOSURE LOG

A number of submissions suggested moving from the 25^th percentile to an alternate benchmark such as median average The submission Avivo recommended that agency:

do not apply '25 <sup>th </sup>percentile' assumptions across all provider types Use model set price caps viable larger organisations supporting agency managed customers and permanent employment.

The submission Empowered Futures argued continue Scheme should be according median or average rather than The submission genU similarly argued:

does use mean or median parameters analysed Benchmark Survey inform Cost Model is achievable half providers participating in Benchmarking Survey.`
Members working group also expressed concerns logic impact pricing strategy assumption prices limits efficient They unclear how quality taken account determining efficient prices Members argue some providers operating lower cost levels may because cutting corners reducing quality Pricing needs address this issue definition efficiency Some members workgroup also argued there single efficient sector best served mixed large smaller individualised local providers Price limits set by pricing strategy necessarily preclude certain modes service delivery especially where those known benefits participant outcomes Members worked group were concerned flaws current method implementing pricing strategy prices Limits assumed no correlation between key drivers provider efficiency means considered only operate 25<sup>th </sup>percentile each domain Suggested better approach measure overall efficiency at total costs achieved rather than the total costs of theoretical provider was operationally achieving 25<sup>th</sup>` percentile every driver Efficiency Working Group agreed annual financial benchmark survey remain basis for parameters survey more granular comprehensive (survey everyone) Providers agree definitions used so comparing apples to apples The Australian Services Union ASU argues NDIS price limits reflect true cost disability support including appropriate classifications performed intensity supported adequate time allocated tasks,

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# DISCLOSURE LOG
## OFFICIAL Core Pricing Arrangements
administration, supervision, training etc.). The ASU submission also argued that the NDIS pricing assumptions should be aligned with minimum Award entitlements and the National Employment Standards including:
- Annual leave for shift workers of 25 days;
- Annual leave loading for shift workers of 17.5% of pay;
- Compassionate leave of 2 days; and
- Community service leave / jury duty of 10 days of paid leave.
The ASU submission also argued that allowance should be included in the NDS DSW Cost Model for 10 days paid Family and Domestic Violence Leave and provide portable entitlements to paid annual leave, personal leave and long service leave. It also argued that the pricing arrangements should encourage permanent employment, including full-time employment:and support training and professional development of workers.The submission from the United Workers Union was also concerned that the Scheme's current pricing arrangements were having adverse impacts on working conditions effective take home pay disability support workers.
By setting these rates at award legally required minima not only does cost model institutionalise low pay but it entrenches these as ceiling rather than a minimum as they are intended...Leave is condition work could improve attract retain worker Based this cost model resultant price employers constrained being able offer above minimum
An issue importance Disability Support Worker factored into costs incurred while doing job This ranges need have up-to-date smart phones or other related technology even consideration type car those workers who transport participants own cars this extends to car-related insurance cleaning costs Other may relate paying items behalf participant While some small add significant burden workers rate part time hours Reimbursement associated with work factor priced model2## Key Parameters Of The Cost Model
### Rates Pay For Disability Support WorkersA number submissions argue base pay assumptions NDIS DSW Cost Model higher Submission Tulgeen example stated assumed SCHADS Classification Level A DSWS increase
difference between 3094 (SCHADS) $3177 ($83 or % so given theoretical margin assumption every hour provided by SCHADS provider negative margin for provider. Is sustainable ...This point issue addressed rating DSW Level mix of SCHADS and would be ideal adequaterecorded: s22(1)(a)(ii)- irrelevant material

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# DISCLOSURE LOG
Ability Options similarly argued that:
> The Disability Support Worker Cost Model does not align with Ability Options' actual workforce costings.
The DSW model benchmarked against Grade Year Social Community Homecare and Disability Services Award at equivalent figure $30 per hour.Paradoxically,
average hourly rate relating service delivery (DSW actual spend)
is more aligned grade year Social Community Homecare and Disability Services Award or an average cost $31 per hour Members also pointed out any assumption below SCHADS level problematic because pay levels tended increase annually workers remained employer until reached . Given need retain within scheme both address workforce shortages experienced staff often provided higher quality support price limits should be based on mature experience rather than rapidly turning over.Members raised concern about low results might artificial included certain providers whose falls home care stream SCHADS awards noted home award rates ranging from - to weekly were lower Social and Community Services award rates ($40 -$50) many do have flexibility pay at home care rates.Members reported some are locked into existing Enterprise Bargaining Agreements EBA difficult renegotiate a rate current in force past their notion expiry date.They also recent trends of providers terminating enterprise agreements.In case members argue notwithstanding difference minimum wages sectors covered by the reality was demanding shifts paid disability sector otherwise would accept those shifts. This may moot shortly when Fair Work Commission finalises work value Case for aged care workers.

## Days Worked Versus Days Paid Submissions also concerns salary related costs including shift loadings annual leave personal long service leave specifically, providers delivering SIL services reported inadequate consideration given model Costs Shift Workers for SIL Support.Providers reported allowance 20 days annual leave Cost Model too low for shift workers entitled as per SCHADS Awards submission Crosslinks Disability Support Services most its providing SIL support is represented by shift workers who represent %

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# DISCLOSURE LOG
## OFFICIAL Core Pricing Arrangements
The submission from Supporting Independent Living Co-operative reported that it calculated that the additional week of annual leave increased fully loaded cost by about **2%**.

The submission from Community Living Options also reported that the Cost Model's:
- ... long service leave assumptions have been made based on the NSW rate for employees working *10 years* is `2 months` (`8.67 weeks`) paid leave; however in South Australia this is `13 weeks`. This variance approximately `$	ext{0}. 	ext{2}$. per hour support provided.`

The submission from Beacon Support raised a number similar issues: Lack allowance if worker works more than ten weekends year, they are entitled to an additional week annu lack allow increase at $^{1}$ . $oldsymbol{	imes}_{i=4}rac{}$ price increase 1.7.21 industry specific long service payments insufficiency and flexibility responding changes sector e.g., portable long service introduced January October costs increased circa $^{{}}$
### Salary-on-costs
#### Employee allowances A number submissions reported provision NDIS DSW Cost insufficient For example Kyeema stated whilst % allowed modelling SCHADS Award allows which mostly First Aid employee Rocky Bay submitted while model assumes weekly first aid allowance standard rate week full-time Mercy Connect said Damaged clothing needs factored into Cost Model with estimating can cost annually i.e approximate Crosslinks Disability Services statement about base salary sufficient cover even one all employe must receive -first-aid allowance The first-allowance-weekly-provided-for-full-time-and part-time-casual employees.

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# Disclosure Log

Laundering only accounts for one element which $\$034; per week or \(per shift).^{1}$
## WorkCover rate
Many submissions indicated that providers are paying higher workers compensation premiums than what assumed in DSW Cost Model:
- Community Living Options stated "providers pay a sector at `rate`%".^{2}
- Empowered Futures stated their current Workers Compensation premium sits at `.9%. and as an organisation they are funded adequately for shortfall."^{3}
- Kyeema stated their ``Workcover currently .07%``.`.{4}`
- Mind Australia Ltd said their ``Workers' Comp is %`.5`
The submission from Minimbah Challenge Inc states: Their ``Premium has more doubled since For small provider, doubling insurance without capacity to engage unfunded additional training unacceptable position be placed when pricing fixed."^^6^
Submissions provided reasons why were relatively high disability sector. The Crosslinks Disability Support Services stated that have due risks associated manual handling infection control behaviours concerns.`^{7}The Council of Regional Services stated risk lost time injuries appears significant prevalent NDIS supports.`8^
Submissions also reported COVID had impact on Workcover Interaction Disability Services reported the assumption Worker's Compensation premium 1.% would suggest incorrect. Impact COVID ongoing protracted periods lockdown resulted levels psychological injury within general community exacerbated within our participants fewer external stimuli become increasingly frustrated times acted out increase incidents work combined with having wear PPE continually months time increased psychological staff These very debilitating take long recovery cost Worker’s premiums escalating not recognised in model.`^9`

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# DISCLOSURE LOG
## OFFICIAL Core Pricing Arrangements
The submission from Greenacres Disability Services reported that the rate of **1.7%** didn’t reflect the realities of serious risk related to COVID-19 in disability supports.
It suggested that the NDIA should use the average premium for the sector reviewed annually as the basis for calculating worker compensation rather than *the* `redacted` percentile.* They suggest that a result workers’ compensation premium assumption in NDIS DSW Cost Model should be adjusted upwards to `.6%.`
Life Without Barriers similarly suggests real allowance Supported Independent Living services should vicinity .
The submission Tulgeen suggested also need amended workers' compensation calculation model providers are also require include allowances and superannuation wages on which they pay workers compensations.
Members working group agreed their organisations were finding impossible bring down workers comp rates below , despite ongoing efforts improving efficiency*
some large employers can't get below given participants homes One member, who part organisation offers aged care disabilities noted could not get their rate below 3%, having improvements claims experience performing better state nationally*. They also suggested cost model recognise varied according types service offered provider noting greater risks participant homes centres.
one member stated cost model consider some providers may self-insured As an insured organisation have more leeway with premiums management enabled them outperform rest external insurer Despite these efficiencies unable bring their premi around % currently
Another member said their rates about partly due claim lasted long time Australian Disability Enterprise includes work does fall disability category (e.g. manufacturing warehousing) further drives up premium.
One of members reported organisation had at level but dilution across other services therapy supported independent living support work Another hypothesised smaller providers either not experienced rated or diversity in nature higher worker compensation rates for disability subsidied lower from business e.g office workers).
members discussed whether it be suitable remove explicit salary assumption NDIS DSW Cost Model instead include implicitly into a figure considered would allow flexibility paying higher worker’s compensation rates,
---
1 Greenacres Disability Services Submission S048 p .5 Life Without Barriers Submision S27 P. Tulgeen Submion S09P.2
## OFFICIAL Page `redacted` of `.`

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# Disclosure Log

or investing in better risk management practices and having lower workers compensation rates.
 A member noted that their organisation had brought down their rates from `7%`to `2%
costs but that that has increased overheads `(due
to stricter recruitment,
higher turnover due fewer employees passing probation).
Another member suggested that this issue could also be overcome by relying on gazetted rates rather than providers were reporting – although can quite different across states as benefit entitlement may vary.`Supervision costs Classification (SCHADS Award)
A number submissions argued current assumption NDIS DSW Coat Model supervisors could employed at SCHADS Awards level unrealistic The submission Mind Australia Limited, example stated: 'Mind employs to provide supervision our staff depending roles undertaken We have found requisite knowledge systems understanding psychosocial theory leadership capabilities not applicants when we recruit below this level.'The genU submitted base salary [Front Line Supervisors] is costed at Level 4 account for realistic supervisor mix supports quality safeguards service achievable half of provider Benchmarking Survey.The Greenacres Disability Services said To attract good Coordinators you need pay above level SCHAHS Award Our preferred position should calculate rate least the model general support work. ... Supers should calculated at Level 3 of SCHADS Award.Greenc further noted attracting good leaders very important supervisory level only achieved levels being or aboveInteraction Services claimed In order supervise with highly experienced knowledgeable and qualified staff might re-visited directly linked requirement provides governance previously comes a cost.
The Empowered Futures submission stated:

1. **Mind Australia Limited**, Submission p..20.
2. **genU** ,Submission p...7.
3. **Greenacres Disability Services,** Submipion p...
4. Interaction Services,",Submiopon p..

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# DISCLOSURE LOG
## OFFICIAL Core Pricing Arrangements
> ... we have found that we need to employ supervisors at level 5 of the Award.
Due to removal complex level support funding SIL supports find ourselves limited 'DSW B' assumptions in current NDIS Disability Support Worker Cost Model These assume supervisor are employed award level We could attract and retain suitably qualified staff pay point Hence organisation funded adequately shortfall.'
Several members working group agreed while assumed base rates disability support workers were adequate but base rates Front Line Supervisors high enough They noted organisations supervise rate much higher than grade DSW Cost Model.
### Span Control A number submissions indicated supervision ratio (ratio per supervisor) not realistic or appropriate especially when considering impact part time casual workforce because FTE can translate into a supervisor being responsible about employees terms headcount Submission reported actual ratios achieved between At lower end spectrum submission from Greenacres Disability Services pre COVID-19 shut down average ratio 6 FTE For Supported Independent Living supports, submissions Life Without Barriers Council Regional Disability Services argued span control assumption is reflective safe efficient services Number subm suggested adjusting supervisio genU suggest span use Financial Benchmarking Survey would deliver efficiencies NDIA The Autism Spectrum similarly recommended change recommendation stated: `The current span untenable there evidence this ratio service viability quality practice significant adjustment needs made so services viable.` Community Living Options called for review ratio assumption statement that Currently CLO providing on average of This variance $3.00 hour provided Financial benchmark survey shows median at indicating the assumptions in need reviewed`

--- FOOTER START ---(footnotes)
[1] Empowered Futures Sub S5 p [2] See Greenacres Mercy Connect Mind Australia Limited Rocky Bay We are Vivid [3] See Life Without Barriers and Council of Regional Disability Services [4] genU Sub s7 [5] Autism Spectrum Australia Aspect Sub S6p .
Community Living Options Sub S10P.
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# DISCLOSURE LOG
The submission from Greenacres Disability Services argued for a **1:8** ratio:
> ...to enable supervisors' personal interaction and observation/guidance of DSWs.
in our view,
supervisors need at least *one* supervisor per eight equivalent full-time employees.*
The submission from Rocky Bay suggested that supervision cost should be reflective based upon organizational size/structure instead of an all-encompassing approach*
The United Workers Union reported employee experience with supervisory ratios as follows:* The assumed model has a `supervisor-to-employee` ration of `.05`. In members’ experiences, this does provide adequate supervision*. A survey found lack thereof to significantly impact health/safety concerns; overall respondents agreed or strongly disagreed (42%) on whether they received sufficient time with their supervisors.`(Source:Cortis,N.,van Toorn,G.Working in new disability markets:A survey Australia’s workforce.University NSW April 2020)` Members had similar concerns regarding adequacy of current assumptions about one supervisor per fifteen workers*, which may not allow proper job performance due higher levels management needed across organizations aspects vary widely within roles requiring more than just the number provided by benchmark data. Working group considered small regional operations dispersed workforces unable meet required numbers without significant travel reducing available supervision hours
Members generally agree headcount rather FTE basis for better outcomes since part-timers/casual staff would still require attention but noted discrepancy between models used.
Working Group argued reduced ratio because high turnover requires additional involvement front-line training and mentoring further necessitating lower ratios.*
a smaller span means fewer employees supervised leading improved results* They also suggested variation among providers service delivery models such as Supported Independent Living Community participation Assistance Daily Living might have different ratios*
The Agency should analyze these differences.

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MR25/01967 FOI 24/25-2242

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# DISCLOSURE LOG

The utilisation rate of **92%**, does not allow for monthly staff meetings essential communication. Nor performance discussion and review activities.
(054%) = days or hours per year). Where in pricing model time permitted worker report concerns about client's wellbeing other work-related issues." The submission from Interaction Services stated that inadequate reasons are:
...the increased quantum practice standards produces an increase training which turn reduces availability" The submissions Council Regional Disability Services Rocky Bay reported their lower rates assumptions with Rockys ranging from %71 to %.3 The Council also said their generally impacted part-time nature support work Several members working group stated organisation currently assumed rate than 92%. One member unrealistic workers given shift change-overs clients miscellaneous client hours they unable bill (e.g., chatting family after dropping them off, picking up cars parking) They median result maximum achieve without sacrificing quality services employee retention A member provided examples additional non-billable hours including team debriefs planning talking supervisor timesheet note taking incident reporting unbilled travel Another noted certain activities e.g.) team meetings training proportionally reduced for part-time casual who would have a lower all else equal Members discussed viability Front Line Supervisor parameter removed supervision costs through other areas the survey open subjective responses different interpretations especially multi-layered organisations Also discussed whether simplicity could be included as overhead loading Member believed good idea concern absorbed into overhead manner makes difficult argue span of control current provides valuable information on

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# Disclosure Log
## OFFICIAL Core Pricing Arrangements
### Overheads
A number of submissions indicated that the assumption of **12%** for overheads in the NDIS DSW Cost Model is insufficient and they are currently experiencing annual overheads between *15* %and *22*. Submissions also consistently argued overheardes increasing due increased management financial administrative compliance costs such:
- Increased governance regulatory complian with the NDIS Commission for Restrictive Practices.
Dealing reportable incidents emergency managemen strategies Quality supervision required under the NDIS Practice Standards framework ensure well governed quality service Associated cost resulting creation new administrat financial IT processes Cost pressures operational regional management rostering, property high cost compliance A confidential submission indicated current corporate costs combined rollout adminstrative challenges have led additional staff costs FTE To support statement submision further noted they: ...currently recruiting dedicated participant funding team manage complexity billing for NDIS participants at a cost approximately $600k per annum as acquiring project teams to facilitate changes business transform meet changing requirements The submission from Mercy Connect noted providers High Intensity particpants have additional overhead costs require staff lodge review incident with NDIS Commisison3. The submissions Greenacres Disability Services Illawarra Disability Alliance suggested provision overhead DS WCostModel should be increased 12tofrom 25% capture overhead costs accurately fairly An increase provisiion overhead model was supported by genU which submitted Agency increases overheads proportionate 25th percentile or **26**%current From this would assist registered provider comply requirement of commissi Members working group discussed separating overheard allowance into corpora overhead relate running standard busines including Work Health and Safety Human Relations etc) fixed operating overhead specific managing disability workforce (including quality safeguarding costs They suggest that is

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# Disclosure Log

commonly known rate across sectors for corporate overheads.
To calculate fixed operational	overheads,	they suggested using	the Financial Benchmarking Survey’s 	25th percentile for	overall overhead rate (	18%) less the	corporate overhead(	(10%)	plus a loadingfor spanof control(if thatis brought directly intotheadverbs).	One member notedthatthis approach will providea more elegant and transparent view oft heoverhead costsand help build astronger argument toi lustrate howtheservice-heavy disability sectorwill have higher overheardsthan other organisations.
## Margin
Many submissions indicated th attha margin assumption o f2%	in NDIS DSW Cost Model is insufficient.For example,thestubmission from genU argued with this levelofofmargin providers were unable to reinvestinto servicesandsupports foreach clients top rovide better experience.[^1] The Illawarra Disability Alliance similarlyargued tha tthislevel ofmargins doesn’t allow investment in strategic planning anda rganisation strengthening initiatives[^2].The submissionfrom Tulgeen stated that 2%margin allowancein cost model ist:
text-align:center; text-decoration:underline;">… inadequate ensure provider havesustainable business (and thereby abletoprovidesome certaintyongoing support participants),"certainly insuffici entto providefor futureinvestment facilities equipment improveexperience enjoyed byparticipants."[^‹]

Thesubmission Council RegionalDisability Services also arg ued forhigher margin.TheNDISDSWmodel assumes a support m argin based on	%of deliverycost. This compares	a reportedsupport marginthe comparable aged care market8 % revenue.If NDIs priceswere adjusted includea margin 	8%revenue(rather than 2%co st) theDWSA core pricegeneratedis $6742 perhour non-SILcore and$70 .42SILbased core.

Thesubmission Community Living Options similarl ystatedthatthe:text-align:left;"> …costmargin assumedby DSWCM is%	baseddelivery service cost.Comparing this toth eagedcaremarket o f8% reven ue.If NDISconsidered changingmarginto bebase don of re venuethis would enable providers greater financial sustainability.[^5]## Other Issues### Allowance overtime in modelSeveral submissions argued thatN DIS DS W Cost Model does not appropriatelyrecognise costs prevalenceovertime sector.For example,thestub mission Crosslinks Disability SupportServices stated:
text-align:center; text-decoration:underline;">redacted</td></tr><tbody>
<tr class="odd">
<td>1<sup>&nbsp;</sup>Ibid., p.&nbsp;&amp;nbs p;.11.</td>
<td>2IllawarraDisabilityAllianceSubmission S&nb sp;104,p. &amp; nbsp ;‹]</td>
<td>3Tulgeen Submission S&amp; nb sp 029p.; 	4Council Regional Disabilityservic esSubmissio ns072,&nbsp;p .8.<br/></td>
<td>CommunityLivingOptions Submis sionS&lt;br/&gt;<span style=

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# DISCLOSURE LOG
## OFFICIAL Core Pricing Arrangements
There are no overtime assumptions built into the Disability Worker Cost Model.
When factoring in
the supply shortages of Disability Support Workers and the inability to cancel SIL supports,
overtime or agency use is unavoidable.`^` The submission from Life Without Barriers similarly argued that:
> There are insufficient allowances to manage a `24/7 workforce`, including necessary usage of casual, overtime and agency arrangements.^`
Members of the working group agreed that the NDIS DSW Cost Model should recognise that	the payment of overtime can be an efficient solution and often the only solution –for example,if aworker does not turn up at shift handoverin asupported Independent Livingdwelling then itisnecessary topaythetnight workerovertimetocontinuetoprovidenecessary support whilea replacementworker istound.Members consideredthat thcost modelshouldbe adjustedto provide for ashareof caretobedelivered through overtimewith itsassumptions.
### Payroll tax Several submissions were concerned there allowance payrolltaxNIDISDSWCostModel.They suggested payrollexistabusiness cost many providers accounted this costmodel.Thesubmissionfrom Council RegionalDisability Services stated modellassumes 0%payroll tax which likely barrier forprofits who pay more than $700.000 wages.Submission BeaconSupportstated
>Payroll taxnot based on profit butbased number staff We currently have approximately185staffforsclientsand haveto significant payroll last year's bill was$438999`^`.We are a medium size businessonly With2profit margin allowed by NDIA pricecontrolsthis eats significantly into profimargin makingmany non governmentorganisations ornon charities unviable.`
The submission from Hireup alsoconcern thatthe costmodelfor many mediumsizedbusinesses subject to paying payroll taxes reducing their profits margins The Cost Model does notprovidefor as most jurisdictions exempt not-for-profit andsmaller organisations from payroll tax.' In `$ billion program is the NDIS,there vast array ofproviders offering services,and many them will be subjected payroll taxasHire upis.In somejurisdictionspayrolltaxis an addedcost almost `to wage workers yet it missing from model`
The submission from Hireupalso stated any move include allowance inCostModel should aware increasing number supportworkers working ABNcontracted sole traders (using online platforms) may notsubject to payrolltaxwell.They further noted if payroll includedinNDISDSWCostModell providers employtheir support workerwould able

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# Disclosure Log

cover the full cost of hiring workers and will also be able to control the number of workers who may not be subject to payroll tax.
## Fair Work Commission’s yearly review of SCHADS Award 2010 Members discussed potential impact changes their costs several noted providers face difficulty changing business practices minimize impact SCHADS higher cost broken shifts but might reduce instances agreed rosters care considered significant adjustments NDIS DSW Cost Model needed extent underlying employment conditions **Broken Shifts** A submissions argued new broken shift allowance provisions commence July would significantly increase costs providers submission Mercy Connect estimated arrangements add additional cost approximately $65k per annum current shift rates The submission from stated: * Broken Shift Allowances must included price structure Given breadth Trust services up all DSW are breaks* Some providers indicated that proposal will increase administration which captured in model This extended need travel between shifts impacted on provided Travel allowances Rocky Bay submitted FWC proposing cap three broken shifts day with additional payable for each subsequent change increases administrative burden however funding doesn’t capture proposed changes Hireup Submission S107 p states New broken shift allowance - one unpaid break attract an allowance standard rate equal currently; two unpaid breaks allowanance standard rate equal Currently Further it no longer permitted employees work more than three broken shifts each day even if they choose hireup particularly affected by this due our choice and control clients support instead centralised inflexible roster system For example worker is working multiple clients a day to simply reduce number broken shifts impinge significantly the choice of both parties

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# DISCLOSURE LOG
## OFFICIAL Core Pricing Arrangements

**MR25/01967 FOI 24/25-2242**

* A number of submissions suggested that an allowance should be included in the NDIS DSW Cost Model for broken shifts, travel between shifts, and administrative burden associated with broken shifts.
The submission from genU proposed a $9%$ allowance rate specifically designed as compensation against broken shifts:
> The cost calculation has been based upon worker rosters over four weeks extrapolated across twelve months; genU estimates such allowances would need to cover approximately nine percent (based on averaging break numbers).

### Two-hour minimum engagement requirement for part-time employees & casual workers
A significant portion of submitted feedback highlighted concerns regarding changes made within SCHADS Award which mandates two hours' work per shift regardless if it's part time or casual employment;
such requirements were deemed detrimental due to participants often requesting shorter durations than mandated,
affecting providers financially since they must compensate even when no suitable tasks are available elsewhere at their disposal during these periods.
Hireup reported more than one-third ($33%)of its clients have booked less-than-two hour-long engagements recently. They noted this trend is common among users: roughly twenty-three percentage points (	extbf{approximately} 	extit{	extcolor[rgb]{0., 1e-5 , .8}{23	extperthousand}}) represent bookings under that threshold each week.
Beacon Support emphasized the spacing issue causing problems where an employee might end up working fewer hours in any given day because gaps between scheduled shifts limit availability, making it difficult and inefficient filling out short-term positions with limited flexibility:
> Having a ten-hour gap between morning-to-evening shifts can make scheduling challenging as some individuals may prefer longer continuous blocks rather than fragmented ones; thus leading into difficulties fulfilling such roles effectively without considering split-shift rates properly included while pricing services accordingly.
genU argued for inclusion $9%$ increase on top of base salary rate (DSW) necessary to account for two-hours minimum engagement requirement being added onto standard pay structure.
The organization currently pays direct support workers according ordinary time rules but has faced challenges providing consistent coverage due participants' varying needs,
such as daily shower assistance or other essential care tasks not always covered by regular shift lengths;
in addition, genU's experience suggests rostered employees sometimes cancel their commitments unexpectedly which further complicates staffing arrangements efficiently managed within existing budget constraints.

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# DISCLOSURE LOG

their shift,
or staff may call in sick,andthe replacementstaff rostermaynot accommodateahour engagementon short notice.
-
itisnot always practicalto provide workin other service types ensureminimum shiftsandwherethis does happenworkers have reduced capacitytosupport high volumetimesslots(morninglunch time and evening),as additional hours can result overtime.
- Support worker shortagescan make difficulttoreally rosterefficiently meet participants' reasonable needs.For example,having a showeror getting outof bed atreasonable timel.
## Remote responsework / Recall toworkovertime away from workplaceThe submissionfromthedisability Trust stated that:
Recall to work/Remote Work for [Supported Independent Living] pricing is essentialforhighneeds participantsof alternativelinclusion plan budgets via irregular funding forthespecific recall instances.
Thesubmission Crosslinks DisabilitySupport Services argued this change award conditions would need reflected NDIS DSW Cost ModelThere decision out support workers remote respond means they will be entitled claim 30 minute allowance if contacted between6:am10pm, hourifbetween am8 pm.It yet determinedwouldneed anotherallowance cost built into thecost modelat very least% increase.2Client cancellationsA number submissions pointed misalignmentNDIS cancellation policy SCHADS requirements causes challenges providers Under NDIs requirementsparticipant cancels appointment more than48hours prior cannot billed even provider has not been able alternative billable worksupportworker By contrastunder newawardconditionsaccordingto submission Rocky Bay
If shift cancelled employee paid amount received hadshiftnotbeencancelled or provide makeup time customer required pay service (in line withNDSI modelcancellationswith hours notice do requirecustomerpay) howeverSCHADSScholarsRockyBay thenrequirefind equivalent shifts workeror pay workerthe shiftMembers working group argue claiming rules in short notices should amended alignnewawards conditions

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# Disclosure Log
## OFFICIAL Core Pricing Arrangements
### Overtime for part-time and casual workers
The submission from At Home Care Pty Ltd indicated that clients often request their care team members to work overtime; however there's no gap between NDIS rates & SCHADS rate compensating overtime.
- **SCHADS award multipliers:** Saturday: x30%, Sunday: X45% Evening: x76%
- **NDIS rates multipliers**:	Saturday: €x1.4,	Sunday: €X1.8	Evening: €X1.1 As complex needs increase, margins decrease due increased supervision needed during these hours ensuring service gaps are avoided where necessary.

Submissions Avivo/Hireup reported real costs paid in line with SCHADS (over %) not included current model. The submission suggested Financial Benchmark Survey should be expanded as detailed benchmark submissions support reasonable estimations of all aspects including overtime allowances on-call cancelled shift payments.
#### 2.4 Claiming Rules
##### Activity Based Transport
A number submitted indicating claiming rules placed considerable administrative burden providers. Rocky Bay stated the current price guide uses unit measure each at $1 rather than km charged per km resulting unnecessary complexity.
The underlying data captured CMS system cannot use native state this results further conversion calculation multiply kilometres by unit rate derive value quantity claim unnecessarily adds admin complexity Perth one longest metropolitan cities terms suburban sprawl important develop appropriate transportation travel pricing particularly for provision disability services transport is key factor providing such service.
## Provider Travel Members working group concerned about claiming rules mean they often can't return travel core provider difficulty attributing travel cost administratively apportion between participants raised issues旅行 limits worker minimum hour to travel locations covered only fifteen minutes.

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# DISCLOSURE LOG

A number of submissions also argued against the maximum provider travel time limits.
For example,
The submission from HelpingMinds suggested that:
> ...the30 minutestravel timelimitisnotalwayspossible,eveninametropolitanenvironment,due
to traffic conditions.... Any travalexceedingtheminutesisanothercostthatfallstotheproviderto\ncoverwhichistonsustainablegiventhemargins."'
ThesubmissionfromQueenslandAlliancefor MentalHealth(QAMH)suggestedthat:\nProvidersoperating inremoteandvery remoteareasof Queenslandface suchfinancialdisadvantage thenthere isno incentivesuchastravel,training,and other incentivesrequiredto attractappropriatelytrainedstaff.'"' Anumberofsuggestionsuggestedthattherecurrent claiming rulesintravels/transportare complexresultingadministrativeburden for providers.The submissionfrom Queens land Allianceformental Health statedthat: \nTransportlineitems arereportedby QAMH'smembers to beparticularlycomplex andthesource 
ofmostconfusion.Therquirementtoclaimseparatelyforthefollow costs associated with transport adds anextralayer administrativ burden needs toreview. Thesubmissionsuggestionalsoconsideration shouldbe given setting price limit whichaccuratel reflectchallenges associativedelivery services rural remoteara CarersACTstatethat:\nTraveltransportshould2 items onlyreflect thedifferent rates depending on vehicle type.
Participants do not differentiate between provider travel activity based transport.They simply want understand how muchtraveltransport cost they have been charged.Wehave asked multiple times simplify our billing but NDISprice guide makes that impossible.\nThe submissions from Down Syndrome Australia arguedtheprovidetravelcostsforallied health professionals reduced more reasonable hourly rate or factored intoNDSI PlanBuild byNDIS planners allow adequate therapy provision."'
## Short Notice Cancellations
Thesubmission We Are Vividargued current short notice cancellation provisions in pricing arrangements doesnot support smart rostering causes

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# DISCLOSURE LOG
## OFFICIAL Core Pricing Arrangements
inconsistent charging for the remaining participants as they end up paying for costs of staff 
not being able to be redeployed.
- The submission from Empowered Futures reported that the ability to claim short notice
cancellation is necessary as there can be participants with high and complex medical needs	with unplanned hospital admissions that require funding to be drawn upon.	The submission by Wellways Australia stated that:
> While in theory we understand the need to have stringent late cancellations policies,	in reality this isn't always viable when working with people with complex mental health diagnosis for multiple reasons... There are potentially significant flow on effects...	For example, a failure by relevant staff
to follow up the reasoning behind multiple cancellations by a participant,...we know can often lead to	people falling through the cracks and missing out on support they need.... Issues like these may cause lack resources appropriate training Staff considerate Participants' Needs.
A number submissions were concerned current short notice cancellation arrangements unfair participants result higher costs providers due covering cost staff rostered work but cannot reallocated. Submission Tulgeen said: ... it's unfair other participants group if nonclaimable cancellation occurs remainders participants required pay ratio usual order cover worker now shared between less participants.
The submission Autism Spectrum Australia stated should not apply 1-to-1 participants recommend weeks exit
notice same others attending Programs of Support.
The submission Gippsland Disability Advocacy stated even though participants 	need paying fee fail cancel before hours appointment provider service without any leaving unable find alternatives suggested more equality decision making.
## Non-face-to-face supports A number submissions NDIS planners do allocate face-to-	face support funding plans participants if providers charge such activities participants may require use funds allocated other supports The submission Exercise Sports Science suggests that nonface-totransport provided generally include review behavioural support plans (which

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# DISCLOSURE LOG

can be up to 30 pages long and supporting participants to understand NDIS and their individual plans.
This additional non-face-to-face work is neither covered in the current model nor is required to be carried out in other schemes."Submission"by Queensland Advocacy Incorporated
Queensland Advocacy Incorporated has been assisting a participant who has complex support needs.The participant has been informed by their service provider that additional funding is required due to the complex nature of the participant's support needs and the additional hours for staff handover and meetings which are required The NDIA has declined to provide additional funding stating that this should already have provided within the participant’s current funding However,service providers stated these additional staff handovers meeting hours beyond what would normally expected from support workers due unique support needs.”The submissions genU Lizard Centre Empowered Futures all suggested Agency needed more guidance on type supports can claimed as non face activities”Time Day Week Members working group were concerned claiming rules did not always line with SCHADS Awards Which potential create anomalies may potentially cause employers underpay workforce For example,SCHADS award indicates when shift finishes after pm evening rate must paid worker regardless length Shift pricing arrangements however are concern about time worker delivers supports each participant submission Bedford similarly argued inconsistencies between SCHADS awards payment arrangement compared NDIS disadvantage provides Example DSW works eight hour Wednesday 2pm10pm providing Access Community Social Rec Activities From they support three Participants (John Joe Mary) attend cooking class And another Participant Patricia attends computer class Under clause Schads DSW Afternoon Shift being any finish after midnight Monday Friday therefore loading ordinary pay must be paid whole such a shift Under NDIS Pricing Arrangements Pricing Limits important consideration when support delivered by participant not work used deliver support. Above shift,Bedford claim Evening Support Patricia because it crosses over between Daytime and Evening Supports but is delivered same worker higher relevant price limits applies entire support However John Joe and Mary Bedfords only claim the Daytime Support must pay worker for afternoon shift The submission proposed adjusting claims so there an

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# Disclosure Log
## OFFICIAL Core Pricing Arrangements
### Night-Time Sleepover supports
Members of the working group discussed the claiming rules for sleepover supports and whether it was appropriate for a provider to bill for the expected number of active hours that a worker works in sleepover shifts instead of the current arrangement.
Some members were concerned about how this approach would cover all aspects related with night-time support issues providers deal within their service delivery model as well as budgeting concerns regarding funding amount being reasonable but every provider could get same amount which some might need more or less depending upon individual circumstances;
members considered these arrangements are currently suitable because they allow planning up-to two-hour active support during each shift; however, predicting exact number is difficult due transaction costs involved tracking system development at participant level making such an effort problematic while also noting benefits associated with known rate among participants cohort allowing better management on per person basis thereby ensuring clear distinction between different types (sleepovers vs nights) provided services.

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# Disclosure Log
## Programs of Support
Many submissions suggested that the **12 week timeline**
for programs support causes administrative burden.
The submission Lizard Centre,
suggested increasing timeframe for Programmes of Support because many participants require more intensive programmes to support their wellbeing and enable them fully participate in environment.It argued reducing admin cost associated claiming after weeks.
Crosslinks which provides Supported Independent Living reported has analyse every participant's SIL schedule every ten weeks complete costing breakdown meet all decision makers have arrangements finalised program signed off within twelve weeks.The submission stated least quadrupled administratve planning time for services added value direct service goal achievement or improved value money.Kurrajong submitted clarification needed on rules claimings for Programme of Support.
### Planning other Issues
A number issues raised about current planning processes.Members working group indicated participant plans funding core capacity building needs funded level provide appropriate support,that funding is constant struggle providers.Following areas particularly identified:
- Lack travel time provider plan.
- Funding planners claiming one worker at once may not align with assessment individual’s needs.
- High intensity supports lack funding.
Members emphasise importance quality safety being able claim multiple workers especially where manual lifting included handovers.WorkSafe perspective requires enough support necessary regardless given level fund.Another member reported another example: e.g. injunction against a provider staff was not handed over situation could act accordingly originally allowed hours day extra hour allowed as part model but reduced 24-hour-plan.

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# DISCLOSURE LOG
## OFFICIAL Core Pricing Arrangements
Members of the working group suggested that planners seem to consistently reject therapist recommendations which are built on managed risks leading people being funded at lower level.
- A member raised issue receiving payments more worker has increased due Plan Managers and Support Coordinators encouraging participants should be charged extra staff despite sometimes appearing service agreement.
### Submissions also concerned rules governing when provider can claim support workers effectively address clients with complex needs clear:
#### Submission HelpingMinds stated current arrangements Shadow Shifts do consider complexities individuals psychosocial disability acknowledge person-centred approach where participant choice Many prefer warm introduction new worker often exceed hour support Unfortunately, turnover common workforce especially supporting participants complexity needs Participants may introduced several Support Workers throughout year limit number shadow shifts providers claim insufficient meet needs participants psychosocial disabilities occasions arise through supporting individuals complex psychosocial needs issues safety risk heightened periods escalated mental health symptoms To ensure Support Worker Participant Safety two-person support would most appropriate responsible course action pricing arrangements include this list examples constitutes Shadow shift The submission Disability Trust suggests: ...shadow shifts beyond 6 hours per year depending Complexity and support needs3...The submission At Home Pty Ltd similarly states: ..., in annual funding buddy shifts is sufficient. It recommended high/complex needs clients significantly increase based multiple carers levels4..Submission Australian Podiatry Association noted case conferences between podiatrists other therapists consultation family/carer or support worker are efficient than billing for phone calls emails the system allow supports claimed single step process provision21

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# DISCLOSURE LOG

> A member also raised a case where their Plan Manager had run out of funds for the provider and participant increased supports without making aware leading significant budget blowout As first in invoice loss left Provider Even early plan review would cover cost that already incurred.

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# Group Based Core Supports

## Disclosure Log OFFICIAL

### Section: Group-Based Core Supports

**3 GROUP BASED CORE SUPPORTS:**

* **41 submissions about pricing arrangements were received in response to Consultation Paper; details provided Appendix A. Working group established from providers and stakeholders met via video-conference twice - Dec '20 & Feb'22 members listed Appendices B. Key topics raised included Value of Programs, Pros/Cons New Pricing Arrangements Cost Delivery Support Program Capital Costs Options Change.

#### Subsection: The Value Of Group-based Programs (Section 3)

A number submitted argued that programs are cost-effective providing value both NDIS participants through spreading costs across multiple individuals while also meeting care goals supporting participant's needs Novita submission stated benefits include opportunities for social connections sense belonging community daily routine out access new experiences maintain learn skills.

#### Subsubsection: Pros And Cons Of New Transitional Pricing Arrangments (Sub-section within previous section) Members working agreed on theoretic benefits enabling more accurate charges non-face-to face time complex clients looking at each type activity determining level support needed run activities acknowledged programs...

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# DISCLOSURE LOG

of support had the potential to drive better outcomes for people and improve quality delivered including through inclusion goal reporting part program they also acknowledged introduction programs supported encouraged some providers review their supports consider how might develop these into capacity building programs Some members working group thought separation capital labour pricing arrangements allowed providers demonstrate participants needed maintain component income maintaining assets Members worked new pricing arrangements designed resolve challenge associated per person allowance non-face-to-face activities However suggested trying solve problem created other challenges Submissions acknowledged that introduced July provided more accurate link between costs individual participants previous arrangements submission AEIOU Foundation example stated introduction current arrangements resulted much granular understanding true 'cost serve' each clients.
However submissions suggested important activities funded from built-in allowances face-to-face were difficult claim under new pricing arrangements included development purchase necessary equipment specialist facilitation enable participants skills interests in group programs (for example washing ironing barista etc.) The Carers ACT submitted:
> With work now needing attributed individuals, providers have little capacity investing time resources into program development.
Submissions said 2020) price arrangement introduced new challenges participant families Specifically: - Uncertainty participation family because unable provide clear ongoing expectation cost due proportion rates3 Difficulty participate track budget plans which could lead over-servicing cases underrating others4 Lack choice control certain groups no longer viable under new pricing arrangements5
Members of the working reported high costs implementing structure including1 AEIOU Foundation Submission S p. .
Carers ACT Submission S ,p.. See Job Centre Australia Limited Merri Health Tulgeen .
See Job Centre Australia Limited and Merri Health .
Down Syndrome Australia Novita Group Supports p..
OFFICIAL Page \_of \\(redacted)

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# DISCLOSURE LOG
## OFFICIAL Group Based Core Supports
* Developing a framework to implement the new pricing structure.
* Developing specific tools to allow site managers to apply three different pricing points.
* Training and up-skilling service delivery staff and support workers.
Members also reported that ongoing increased administrative burden and complexity were par or outweighed income received from non-face-to-face components in price arrangements due to increased admin burdens including:
- Using multiple line items planning developing schedules supports invoicing operational calculations,
- Undertaking goal reporting activities such as justifying supports Plan Managers Support Coordinators disputing when invoices are paid Members complained lack understanding among these roles led rejection of invoices increasing debt.
An increase risk error claiming associated with using multiple lines this creates additional administrative burden resolve.
Working group members concerned time otherwise could be dedicated providing better services participants asked for simplicity Pricing several submissions providers suggested if mandatory would result reduction available programs placing greater pressure NDIS social isolation disconnection participants submission Rocky Bay example stated: `the new pricing arrangements make it difficult profitably offer group programs their added administrat complex This detrimental choice control importance group well-being` Many concerns raised moving 20 (20) pricing arrangements negative impact sustainability Some modelled significant deficits. Confidential suggestion risks higher currently high levels uncertainty disruption COVID restrictions workforce mandated vaccinations Another confidential projection net loss projected increases revenue NDIS Life Without Barriers acknowledged can addressed by utilising the new items face-to-face costs however, process consuming complex It said:

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# DISCLOSURE LOG

COVID19 and the subsequent suspension of business-as-usual operations delayed assessment implementation of new group pricing arrangements Alliance members' cost analyses indicate estimated reduction revenue... The potential adverse impact moving 'old' inclusive per hour direct service provision centre capital need be claimed separately This headline loss income can addressed time consuming complex administration claiming processes.
Some working also associated with decrease in revenue they found costs their group-based core supports could recouped ability charge non-face-to-face time One member used analogy explain increased complexity under new pricing arrangements They compared arrangement hypothetical situation where NDIS ran bus service charges that split between fuel driver assets overheads It suggested provider would require adjust price depending number people got on it Was suggested not practical transport market hence questioned why thought this practical for group based core supports.
## Increased Overhead Costs Administrative Complexity A large submissions indicated introduction had administrative burden providers Members reported additional activities such as:
- Identifying calculating each participant's face-time
- Explaining reducing ratios when participants do attend, non-face-to-face supports to families resolving disputes when challenged,
- Gathering sufficient evidence record varying throughout day including charges support services,
- Determining whether a is applicable or not basis ownership premises
determining prices different staffing within systems designed accommodate model.
---
note: 1 Life Without Barriers Submission S27 p.4 note: See Ability Options (S218) Australian Community Industry Alliance Autism Spectrum Australia Bedford Carers ACT Crosslinks Disability Support Services Down Syndrome Illawarra Disability Jobs Are Us Job Centre Kurrajong Life Without Barriers Mind Novita Group Supports).

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# DISCLOSURE LOG
## OFFICIAL Group Based Core Supports
* Manually checking the claim is correct across multiple line items.
* Manually adjusting invoices to include separate line items: direct service provision; non-face-to-face supports and capital.
The submission Crosslinks Disability Support Services stated that:
> With proposed changes splitting hourly rates would need charge non face time hours cover extra planning preparation This becomes another administrative task identify who worked plan how much spent participant When you have coordinator arranging these events two four people difficult idenitify non face charges The Carers ACT reported implementation new pricing model will create significant administration burden Applying we now must calculate number workers x hour rate divide participants establish amount charge Without item code each ratio staffing no way set up system manually enter description on every invoice raise or make this mean our processing take many more hours ...3 The Kurrajong similarly reported calculation separate non face charges centre costs then has increase admin [sic] time providers as it tripled products chosen calculated in turn explained when signing service agreements4 Community Living Australia indicated group service structure components of support worker elements does not provide any benefit provider (in opinion) services do operate succinct groups times tasks Support workers perform elements throughout day5 Providers also suggested increased complexity risk claiming errors Rocky Bay submitted administration potential from fraction an hour customer based ratios rework needed change6 Some submissions estimated impact moving price arrangements for group supports concluded the model would not their operating cost A confidential submission expected total corporate program running group programs to combined 18.4% revenue result pre-2020 post-2020

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# DISCLOSURE LOG
## EXHIBIT 2: PROVIDER ESTIMATE OF THE IMPACT OF MOVING TO THE 2020 GROUP-BASED PRICING ARRANGEMENTS
| Item | Current Program Overhead | Current Corporate Overhead | Projected Program Overhead | Projected Corporate Overhead |
|-|-|-|-|
| Senior Management Costs | **1.**% | *1.*% | ***2***.% | *1.*%
| NDIS Quality and Accreditation | .3*% | *.6****
%. | .*5*
*. | *
*. 

.
| NDIS Compliance and Incident Reporting | .4*r*
*n.| *.7*****
%n|. | *.5******
*m||
| NDIS Funding Recovery | .7*h*g|r*s*y*i*c*k*l*t*u|m*a*b*e*d ||&nbsp; &amp;		;&nbsp; &amp;nbsp;</td><td>
| NDIS Plan Administration | r********a*******i************************m*p|h|i*z*w*q*v*f*x*j|x|l|e|s||||
| Participant and Stakeholder Liaison | m*&lt;a&gt;i&a#x00f8;z|#b#x00f8;l##c###d####e#####f######g#######h########i############j################k########################l############################m###################################o#
#. #z&&y$u$v$t$r$s$q$p$o$n$m$l$k$j$i$h#g$f&e$d$c$b$a|
| Human Resources | 1.**3**% | **1***.% | ***2***.*% | *1.*%
| Marketing | .*5*% | *.6****
%. | .*5*
*. | *
*. 

.
| Finance | .9*% | *.4*r*n.| *.8*****
%m|. |
%n;. 

.&nbsp;<td>&nbsp; &amp;t&amp;s;tp; </td></tr><tbody><tr class=

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## Source release page 602

# Disclosure Log
## OFFICIAL Group Based Core Supports
Members of the working group also argued strongly that the overheads associated with running a group-based program are **not** the same as those associated with running a non-group-based program and that the `12%` overhead allowed in the Disability Support Worker cost model *is* insufficient.
In addition to these costs, submissions suggested new pricing arrangements will further increase service delivery due factors such as ongoing need explain arrangement participants families; process invoices increased granularity complexity ensure compliance NDIS pricing rules resolve disputes claiming errors.`^1`
### Programs Of Support A number considered Program support were welcome addition price arrangements acknowledged programs have been useful secure financial viability activities manage cancellation risk.^2 However many providers suggest week timespan for Programs Support is restrictive causes administrative burden cited additional administration renew update Program every weeks participant ratios change client cancellations or changes staffing (which has particularly challenging isolation requirements associated COVID-19 pandemic) suggesting impractical.`^3 An example impact on provider's costs given submission Autism Spectrum Australia follows:
The claims rules for reducing ratios when participants do not attend very challenging explains participants their carers because costs constantly changing makes hard budget over 48 weeks CRM this required significant modification added technology cost margin.``
A number reported Program administratively costly implement Agency provided information regarding how can be implemented operate practically The Kurrajong submitted:Program require more clarification Pricing Arrangements Price Limits Providers require clarity claiming rules Employment

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## Source release page 603

# DISCLOSURE LOG

Strategy: Providers were informed that all supports could be added together; so weekly claims would match SIL.
It did clarify that this cannot apply other Programs Support. Now providers are questioned around claiming Program Supports which unfair when guidance unclear and trying comply rules."^" The submission from Tulgeen similarly reported:
There insufficient information or guidance currently available how programs can implemented in practice For example participant withdraw with weeks [sic] notice but no guidance such withdrawal affects pricing remaining participants group.^ Some submissions highlighted challenges operating a Program Supported Independent Living (SIL). Specifically Crosslinks Disability Services suggested they require analyze participants' Schedules every week quadrupled administrative planning time services "". Τ Rosters Participants arrangements change frequently however these changes usually minor cost impact material However program support must regularly tweaked ensure transparency accuracy current process stands This results conducting breakdown everyone's schedules complete costing meet decision makers have finalised signed off within 12 weeks has minimum quadrupled administrative planning time for services that way added value to Participant direct service goal achievement improved value money Other suggestions suggest funding management pressure on participants Minimbah Challenge Inc issues was particularly acute where their primary residence is home requiring funding support periods absence still billable through Program of impacting funds availability A number submisions allowed timespan should extended beyond weeks specifically Novita suggests extending period over which could operate
... catered individuals annual program supports fixed rate reduce overheads all parties Submission Autism Spectrum Australia also suggested if agreement set ratio then this ratio charged duration regardless who attends weekly Additionally some submitted

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## Source release page 604

# Disclosure Log
## OFFICIAL Group Based Core Supports
Further clarity and guidance were required relating to the claiming rules associated with Programs of Support.
### The submission from Beacon Support suggested that:
> ... programs of supports should be automatically built into SIL supports, whereby a provider is able
to charge for a support regardless of whether the participant is there or not,eveniffor amaximum periodof time.`
Members ofthe working group held mixed viewsonprograms ofsupport.Somemembers indicatedthatthenew arrangements increased administrative burdenand complexitywhichwas compounded where therelais also aprogram ofsupportor service agreementthatisrequiredtoreview regularly everyl week.Thesemember consideredthatwhileprogramsof support work wellfortargeted capacity building needsadministrativeburden isnecessarilyincreased whenneedsandoalson’t change.Members suggestedithe referenceto atypical patternofs upports”for programso fsuppor tin employment serviceswasa simplerandsensible approach,andquestioned why this language hadnot been used`\nforprograrns ofs upport ingroup-based coresupports. Some members oft he working grouphaslo sugg ested their consultationswith participantsafamilies identified concerns about how complex it was t explain andnavigate thene wpricingarrangements.This issue wa scompounded wherether were multipleparties who would need tobe involvedtosign off on new agreementsincluding carers guardians,the Public Trustee etc.Memberson have nol implemented programs ofsupporth reported thatthisis often due topush back from families aswellastheadministrativ e bur den associated with implementation an ensuring they remain uptodate Members alsosuggested th Plan Managers a nd Support Coordinators don't understandprograms os sup port.
Membersof theworking group suggestedthe processesassociatedwit h pro gramm so fsupport could besimplified,decouple front end calculationsandback en dinvoicing avoid therequirementtorepeat administrative activities.A monthly or quarterly invoicewas sug gested.`
title:

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## Source release page 605

# Disclosure Log
## Options for change
To reduce the complexity associated with the pricing arrangements for group supports, several providers recommended that price limits revert back to those in place prior to July 1st, 2020.
- The submission from Crosslinks Disability Support Services suggested:

The current rates remain unchanged because they cover transactional costs more simply and avoid charging non-face-to-face time which increases these costs.```

Illawarra Disability Alliance proposed introducing a loading system based on additional participants: a standard amount would be allocated within hourly rates reducing overheads while ensuring sustainability through minimal transactions or record keeping requirements, suggesting an introduction at ratios such as (e.g.,) 1:3, etc. Kurrajong’s suggestion included allowing fewer line items across categories rather than setting specific ones per category; this simplifies confusion between Participants/Providers alike. Bedford emphasized clearer guidance regarding how Non-Face-To-Face support claims can be made since splitting them into separate lines has complicated justification processes; case studies could help clarify usage examples. genU supported retaining new(2020) pricing structures due to transition cost satisfaction among participants. Novita suggests expanding Program durations beyond weeks if transitional arrangements are not continued. note: This document was released under Freedom of Information Act by the National Insurance Agency.

DISCLOSURE LOG

OFFICIAL Group Based Core Supports

Submissions also reported that the move to the 2020 group-based pricing arrangements had required providers to incur costs in redesigning or modifying their claiming, invoicing and/or customer relationship management systems to accommodate additional complexity. This has often required involvement from external software developers… The submission Vision Australia estimated a cost associated with implementing new system development needed $$76{,}543$. This breakdown across scoping requirements solution design building testing preliminary change management They stated:

…the systems development costs introduced have been substantial internal effort involved both Vision Australia and our invoice platform… The above data does not account opportunity cost doing other important work planned. Further concerns were raised if agency again significantly altered these arrangements they also noted insufficient support notice transition Novita suggested arrangement announced without consultation caused significant upset disability sector undermined future confidence Submissions highlighted lack education training associated transitioning new price arrangements Job Centre Australia Limited submitted: since introduction of July 1st there has no training provided NDIA Providers Participants Coordinators Support Plan Managers Additionally submissions indicated Agency information lacks detail necessary plan implementation most changes being at too high level lacking details for Bedford reported confusion participants communication NDIS resulted some rejecting costing framework non-face-to face supports identified separately genU similarly reported

DISCLOSURE LOG

Poor / non-existent communication from the NDIA to participants informing them of the change This was left providers communicate reasons changed additional cost absorbed genU spent many months providing forums workshops individual communication participant families changes understood guidance provided NDIS providers vague time taken transition new model longer anticipated Fortunately recognised date shifted out The submission Novita suggested provide certainty participants providers future investment should commit long-term pricing framework They stated commitment road map group based pricing supports would give clarity about environment confidence invest significantly increase Members working also called more certain in Pricing arrangements require a pricing framework allows sign leases (i.e., years) with some certainty Providers seek roadmap indicating what landscape will look over next few years, degree Certainty investing without risk that arrangement will again Members requested continue multiple options for how programs charged and be able choose approach adopt Under current price guide once have transitioned new pricing arrangements core support are not able move back It argued need removed Some prefer operate group-based core supports previous while others invested capital want move back Also expressed desire Agency acknowledge daily support providers Group support workers experts field increased trust sector Working members identified challenges associated interactions Plan Managers Support Coordinators Express concern visibility plans led debts where funding exhausted Members indicated perception Plan Managers Support Coordinators policing Scheme often insist detailed itemised accounts justifications which administrative burden providers acknowledged managers consider reasonable necessary including scheme sustainability value money However concerns systemic underfunding expertise of support workers unduly challenged recommends denied

DISCLOSURE LOG

OFFICIAL Group Based Core Supports

It was suggested that there is a tendency for Plan Managers to shift participants from complex to standard funding arrangements, or to non-centre based funding arrangements when this is not what that participant either chooses or requires. Members of the working group argued this was evidence of a need for increased education/guidance for planners, participants and Plan Managers. Members suggested that education in the space of non-face-to-face supports was lacking – both among Plan Managers and Support Coordinators as well as participants and carers Some members suggested a guide from the Agency covering what non-face-to-face supports can be charged for would be beneficial.

Disclosure Log

OFFICIAL

Temporary Transformation Payment

Some submissions about the Temporary Transformation Payment were received in response to the Consultation Paper. Details are provided below:

Support: The TTP has supported costs associated with reinvestment and transformation initiatives;
Barriers Accessing and claiming barriers have been identified; Future considerations include alignment requirements, testing systems, developing non-face-to-face support tracking mechanisms, analysing business processes.

DISCLOSURE LOG

OFFICIAL Temporary Transformation Payment

The submission from the Disability Trust was also concerned about the implications for their system costs of changes to Agency rules and process. There has been recognition that our overhead structures must reduce in order to compete; however beyond TTP up-lift there hasn’t yet had adequate stability within NDIA’s operating pricing guidelines design processes build configure systems It difficult just transact first place continually find ourselves reacting shifts ndia processes^1^ The submission Avivo indicated they believed transformation cost were ongoing temporary related limited period tended offset higher areas quality safeguarding technology license cloud storage cyber security recruitment retention etc… to meet quality safeguards requirements Avivo established Practice Support team includes Positive Behaviour Specialist supervised external Clinical Psychologist We have invested training colleagues provide this service as well developing our guidelines materials around positive behaviour support restrictive practices Any revenue we may ultimately claim area will be immaterial compared with cost Also now incur $145 per person worker screening national police clearance still required aged care mental health funders pay employees complete NDIS orientation module^2^ The submission Crosslinks Disability Services raised similar issues…the NDIA changed rule processes providers subject throughout significant ways little notice For example program supports SIL hourly claiming rate cuts separation travel participant transport group rate change cancellation changes This requires IT system changes resources manage these ongoing rule changes. Crosslinks does not believe loading achieved purpose believes without it Organisation sustainability would further jeopardised^3^ The submission Sylvanvale similarly argued billing complexity created by NDIA pricing arrangement itemise Group activity funding into support capital allowance non-f2f has significantly increased[d] the Provider admin effort costs to transact TTP continue help Providers meet NDIA report and billing requirement^4^ Other submissions reported that providers had already committed investments improve performance next two years on basis continuation of TTP originally announced The submission ONCALL suggested there shouldn’t early withdrawal from TTP pricing detrimental those providers actively improving systems ensure positive outcomes participants^5^

— FOOTER START — note: 1 - The Disability Trust, Submission S159 p. ote{The text is a reference but lacks page number} . ote{This appears as an OCR misreading; likely intended

DISCLOSURE LOG

The submission from genU reported that payments received through TTP will help them invest about $2 million in new rostering and payroll systems. Not all providers supported continuing these arrangements; Paragon Support Limited stated they should get rid immediately due to price gouging.

DISCLOSURE LOG

OFFICIAL Temporary Transformation Payment

… providers often do not charge TTP because it will disadvantage participants who have very tight funding budgets. This then disadvantages them further when they are unable to claim payments but must participate in all requirements such benchmarking surveys which cost associated costs. The submission from Carers NSW similarly reported that: as prices were increased without indexing Participant plans many providers have been claiming against services provided due fear impact participant plans which haven’t yet reflected increase pricing caps. Several submissions reported can prove disincentive as higher price limits reduce number hours available a participant’s plan meaning less competitive market The submission Merri Health reported some difficulties explaining additional cost TP provider Mercy Connect reported that:participants forced choose non-TTP or receive support as TTP more expensive Several recommended should be disadvantaged choosing TTP genU stated that:funding for [should] ensure they aren’t disadvantaged choosing eligible to claim TTP Action on Disability within Ethnic Communities (ADEC) similar recommendation is TTP support shouldn’t come at expense rather directly NDIA encourage newer providers promote growth Beacon Support reported first introduced indexed include TTP was quickly removed after indexation period and now left with reduced choice control While NDIS states funds if run out usually isn’t case Providers also concerned advised by Coordinators other intermediaries, well staff occasion allow the provider charging TTP Wellways Australia submitted

DISCLOSURE LOG

… had incidents where some Support Coordinators have attempted to put pressure on Wellways staff to provide quotes with TTP removed in order to increase the value of the participant’s plan.

The submission from The Disability Trust similarly stated that:

Large providers are also subject to Support Coordinators steering clients away from TTP-providers to address an ‘underfunded’ plan. Rather than addressing the issues with the plan we have witnessed behaviours move non-TTP providers despite client being happy existing arrangements.

The submission At Home Care Pty Ltd similar argued that:

Although NDIS allows claiming rates they do not adjust Individual Client Service Bookings enough funds enable provider claim TTP… Clients advised find non [sic] providers. Several providers supported independent living supports reported difficulties arise because is applicable their services. Submission Rocky Bay stated this inconsistency makes it more difficult negotiate customers who may be provided across both areas. The submission Paragon Support Limited similarly reported that: TTP favoured few external providers able while other providers, like SIL just accept what deemed unacceptable level funding It totally unfair funding stream…. NDIS does support participants extra funding if service providers use claim TTP Just means less burden SIL providers cover hours funded by TTP. Members working group argued Review needed carefully consider meaning statistic fewer half (by dollar) all eligible were billed inclusive TTP Providers warned this might reflect sustainable delivery but market power held in current arrangement. The working group considered underutilisation of items was artefact planning which builds plans on assumption prices governed exclusive price limits Plan Managers overstep role influence participant advising them not accept limit because it did line how had been made. Providers long standing and trusting relationships with also claim duty care mean reduce price for a below break-even point rather than number hour support funded plan particularly where those maybe necessary such as personal care increasing

DISCLOSURE LOG

OFFICIAL Temporary Transformation Payment

their prices to the level allowed by the TTP arrangements. the majority of working group did not consider that they could continue absorb costs in way.

Future of the TTP

A number submissions argued have achieved their purpose and been successful promoting competition increasing capacity providers ever-changing market increased provider expected generate positive outcomes participants through availability supports greater price These also argued there ongoing need support further development submission Hireup stated:

Now pandemic restrictions reducing many are finding new services challenging predict client loads TTP can assist businesses prepare The will be important support as participants fully adopt their services scheme. The One Door Mental Health similarly submitted stating: temporary transformation payments helped ODMH develop capacity noting rate payment reduces significantly until phased out on July 2024 …TTP help recover from impact COVID which benefit participants ensuring specialist responsive continues At minimum, continuing existing schedule for rollout TTP.The genU argued submitting money spent this transformation positively impacting participants assisting genU deliver efficient into future.Many supported continuation loading generates additional revenue enabling service providers quality cope with significant financial administration costs increase transaction maintain systems processes align NDIS policies National Disability Services strongly arguing NDIA should honour commitment reduce only at per annum Many relying upgrade funding remove quickly would harm relationship between providers and NDIA.Autism Spectrum Australia stated TTP supporting organisations provide high quality particularly delivering Programs Support necessary infrastructure Given how it is to provide services area inadequate any additional funding delivery.1 Hiruep Submission S107 p . OneDoorMentalHealthSubmissionS97 genUSubmissionS219 NationalDisabilityServicesSubmissions152 AutismSpectrumAustraliaAspectSubmissionS66

DISCLOSURE LOG

The submission from Vision Australia similarly argued that:

The TTP has been instrumental in rendering these services more sustainable, particularly providers who work thin markets low incidence cohorts. The submission Tulgeen suggested removing loading would have drastic impact most registered regional-based leading significant reduction service quality choice participants. Providers felt there be value maintaining TTP recognition different services delivered by and unregistered Providers Submission Jobs Us argued: Currently item groups this financial incentive between being a NDIS provider non-NDIS provider pay thousands dollars audits maintain standards needed receive registration similar provider compete does go through difficult recommend continuation TTP3. The submission Tulgeen similarly argued registered provide with higher quality support greater control than unregistered providers, removal rates unregistered providers (generally individuals) gain undue competitive cost advantage Therefore improve cost efficiency for recommended as an incentive encouragement permanent additional price limit margin should introduced instead current TTP loading4. The submission Action Disability within Ethnic Communities also recommended continued post 20245. The Merri Health submitted TTP eligibility requirements increased reported currently no outcome or benchmarks organizations achieve to receive payment missed opportunity enhance market Quality of providers submit could replaced incentives based on positive outcomes achieved argue This allow providers competition volume rather purely model involve set price limit then funding measures thus encouraging innovation delivery high-quality supports6 Members working group considered principal purpose the was assist meet costs transforming systems able transition

DISCLOSURE LOG

OFFICIAL Temporary Transformation Payment

MR25/01967 FOI 24/25-2242 into the NDIS.

In this regard members of working group advised that additional costs associated being registered provider in NDIS were permanent and increasing over time while some transition might have been expected temporary investment new accounting or staff management systems continued necessary Scheme still steady state administrative regulatory arrangements concerned One member remarked they trying automate as much claiming administration could substantial new investment whenever requirements agency Commission changed Members also advised new costs arising For example cost liaising with NDIA reporting incidents accidents safeguarding issues commission audits accreditation investigating rejected claims resolving including credit control (bad debt) costs self-managed plan managed participants advocating for supporting participants their reviews software licensing cybersecurity etc Concerns raised reduction TTP below current level mean did not adequately compensate ongoing changes Agency Commission other regulators making increase admin requirement within scheme Some members working group suggested NDIS Disability Support Worker Cost Model does reflect true operation unlikely TTP enables true costs delivering services registered provider covered More than one indicated considered even inclusive rates already insufficient cover operational Specifically argued core business elements such quality safeguarding are reflected model As result many providers using stop gap measure partially offset community participation if removed before correct model would survive particularly regional areas those servicing high intensity participants middle band by size most at risk unable to without TTP because achieve economies scale which distribute adjustment investments The TTP arrangements acknowledged provide support enable providers invest establish systems part transition environment Additionally, some of the working group indicated that arrangement assisted

DISCLOSURE LOG

organisations to implement ongoing changes to agency’s rules and ways operating The working group considered that TTP arrangements were few initiatives Scheme through which government invested sector support efficiency innovation implementation reform It suggested currently little innovation occurring in primarily because any direct surplus generated used cover unfunded plans being absorbed overheads pricing does reflect true costs operation adapting scheme Some providers argued current transactional environment can be achieved with support or another form dedicated funding Members also argued depth diversity provider landscape important strength viability However led differences cost structures example between who offer variety services those specialise Working group boutique smaller could cherry pick” “services worked their structure larger more easily absorb however noted above working due transnational nature Scheme economies scale not achievable as get bigger. The working group considered there is an need balance for efficiency maintain quality lack increase both adjacent areas it suggests some supports local innovative responsive providers danger one price fits all approach would drive towards aggregation at expense Diversity members transition transformation likely continue efficient scrap TTP recognise these operations core supports This have advantage of both funding incentivising innovation reducing complexity claiming negotiation Some members consider maintaining separate loading base limit allow Agency reward/incentivise investments desired area modifying eligibility criteria TTP to make regular substantial changes its rules the way should either:

Remain place level assist required meet associated costs; or Be replaced by higher set prices recognised ongoing nature addressing changes procedures agency NDIS Commission On balance favoured second option addressed other issues that providers faced including barriers to charging rates inclusive from Plan Managers and Support Coordinators quoting rates inclusive; better aligned planning arrangements

Quality and Safeguarding Costs

Disclosure Log OFFICIAL

Section: 5 - Quality and Safeguarding Costs

MR25/01967 FOI 24/25-2242

A total of submissions about costs ensuring quality/safety supports people disability received in response Consultation Paper Details Appendices provided Working Group providers stakeholders established had members organisations met video-conference times February March.

The key topics raised consultations were:

Provider registration ongoing compliance audits;
Practice Standards;
Incident restrictive practice reporting;
Training professional development;
Supervision; other issues.

Subsection: Provider Registration Ongoing Compliance Audits (Section) Many submissions reported Commission’s provider registration process administratively burdensome costly sometimes requiring third party support Paragon Support Limited suggested that should employ staff conduct audits avoid need for providers engage overpriced auditors They also suggested if anything the auditors supportive new companies rather expect perfect documentation supplied a third party with their name on cover Several providers expressed concern auditing requirements maintain accreditation extensive both financially terms time resource requirements Australian Community Support Organisation highlighted lack funding mechanism to support auditing suggesting There is no current pricing arrangement account additional NDIS audit costs registered organizations remain accountable high level service provision Number submisions case studies direct indirect costs ongoing compliance audits Ability First reported etc. See Allied Health Professions Australia S111, Australian Physiotherapy Association S098 Avivo S112 NeuroRehab Allied Health Network S068 and Paragon Support Limited S208 2 Paragon Support Limited Submission p73 see Allied Health Professions Australia S111 Australian Community Support Organisation S082 Avivo S112 Beacon Support S022 Council of Regional Disability Services S072 Exercise Sports Science Australia S070 genU S219 NeuroRehab Allied Health Network S068 paragonsupportlimited S2084AustralianCommunitySupportOrganisationSubmissionS082p.

OFFICIAL Page:57Pageof1049

DISCLOSURE LOG

The full cost of participating in the three-year NDIS audit cycle for our member organisations is, on average, $1.·M ªdwiththehighestcostreportedbeingjustunder$£4M.Thisequates oanaverageof( \text{ } )%corporateoverheads with a high of $4.%$. The cost doesn’t just lieintheaduititself; there are significant expenses insalarys, internal auditing IT costs paying staff attendaudit interviews policy and procedure developmentand ongoing monitoring compliance work quality team.$^{ ef {footnote:MR25/01967 FOI}}^{[1]}$

The submission from Council RegionalDisabilityServices WesternAustralia noted that higher price limitisrequired to cover:

…thefullerNDISqualityandsafeguardingcompliancecosthigherstafflabourcostsincluding salaryforstahousing lackapplicationgeographiclensplanningorhighercostswithprovisionofsafetysecuritywhichareimpactedbythesignificantlyhighecratemoregionalremote communities.{$}$$^{{}[ 2 ]}$They reportedthatExamples of costs incurred by some largeorganisations prepare support the audiprocess rangefrom$700Ktounderstandingcommission in WA has resulted sector concerns about increasing costs additional administrationregulation loss capability expertise within State Government.{${}{ [{}] }}$ ThesubmissionCouncilRegional Disability Services also quoted research at UniversityWestern Australia showed increases compliancetotal costs increased by %£%.´%·in $2019-2020 ªdand( \text{ } )%. The submission NeuroRehab AlliedHealth Networkreported direct costsexternalauditors’ amountto~$10,000 per annum Indirect costs are significantly highertaken minimum hours senior management time review and update policies ensuring they current with practice standards In addition Psychology Clinical Manager Team Leader have each needed spend around hour reviewing policy updating team members appropriate BSP knowledge This is both costly from wage perspective but even morecostly lost revenue aspect.$^{[5]}$

The submission Avivo reported recent months Avivohave been receiving audit files requiring significantreview down to source documents before responding relating several hundred claims Eachtime deadline for responseis weeks. Thissubtracts resources usual responsibilities those twoweeks{$}$$^{{}[6 ]}$Providersalso made number suggestions as how thecurrent quality safeguarding arrangements could be improved reduce unnecessary compliance activity

DISCLOSURE LOG

OFFICIAL Quality and Safeguarding Costs

whilst still ensuring that services were safe and of the highest quality. In particular Ability First suggested: prior implementation major changes compliance requirements NDIS Commission should undertake cost analysis share NDIA requirement provides appropriate financial support providers implement… The NDIA work with providers navigate its systems prior rolling out any new changes particularly when they are seeking reduce complexity… Members working group also concerned costs quality audits describing them extensive both financially terms time They reported audit requirements seemed better suited larger providers smaller allied health professionals A particular issue travel (including accommodation meals) auditors rural remote locations One member stated experience audits performed two auditors Rural practitioners unable undertakes certification because cannot cover travel costs two auditors Also noted not always easy match up another provider same area get audited together timing audits Members working group individual allied health professionals already well regulated their own bodies which have codes conduct ethics standards Some members thought this essentially duplication The Review notes however, commission registers rather than individuals unless practitioner is sole trader Several members working group shared high increasing compliance costs One member reported organisation five full-time investigators paid $100k year minimum each but struggling keep 24 hours respond reportable incidents Another added additional costs associated paying overtime in particular where responses need to be addressed within 24 hours Member working group reported quality safeguarding costs gone from .3% revenue In past year reported increase of %500 Commission costs Another reported incurred policy team training supervision model management incident investigation management Additionally invested millions client management system engine room for clients

Practice Standards While providers welcomed robust practice many suggested number NDIA’s practice standard excessive For example Ability First reported:

Under NDIS Commission service provider registered deliver most core supports will required certified at least min. stds and indicators irrespective ”Ability First Submission S229 p.

Disclosure Log

Submissions reported that each amendment to the standards requires investment to implement, which adds to the growing cost of being a registered provider. genU\nfor example, reported \that implementation new practice standard can require establishment team people understand translate procedures develop supporting policies training materials deliver in house training support providers participants and their families optimise systems develop mechanism monitor business’ ongoing adherence.The submission from Avivo similarly reported they had established Practice Support Team including Positive Behavioural specialists supervised external Clinical Psychologist ensure adhere delivery safe quality supports This team develops policies trainings materialsto support workers participantstheirfamilies With respect most recent Practice Standards genU stated: The NDIS (Quality Indicators) guidelines have just been amended include three new practice standards Mealtime management Severe dysphagia management Emergency disaster managemen The new practice Standards Quality Indicators were released week before Mealtimemanagementpracticestandard commenced Newstandardsrequire extensiveinvestment specifictraining Ability First report undertaken initial estimate impact training costs comply with new Mealtime Management standard Trainingcostsare estimated between $1750 2M depending numberparticipants staffaffected For one member this impacts approximately300participants. Traininorganisation become compliant such short period time has not beecosted by Commission nor factored into any pricing adjustments NDIA Anumber otherproviders also suggested thatnewpracticeshave increased operating costsmetiqualityand safeguarding requirements ParagonSupport With the new mealmanagementdisasterplanning companies will need spend hundreds unpaid work hours developing plans organising OT Occupational Therapists perform assessments None ofthisis funded Another provider made confidentialsubmission along same lines:

DISCLOSURE LOG

OFFICIAL Quality and Safeguarding Costs

There is no allowance for the cost of implementing and embedding new quality and safeguarding measures. With new additions to practice standards launched in November providers continue to stretch themselves react yet another way working Members work group echoed concerns that practice standards other regulatory arrangements were often released imposed without sufficient attention costs timing implementation In particular members agreed introduction meal management practice standard had taken account shortage professionals available undertake necessary assessments especially regions many participants did have funding plans pay assessments 5 Incident restrictive reporting The Cerebral Palsy Alliance provided detailed view how much has changed terms reporting compliance activities New South Wales Commission commenced This includes extension requirements from incidents allegations incident people disability who lived supported accommodation all participants along expansion types reportable events below managed operational team There four categories ‘reportable incidents’ involving people with disability a) Employee client b Client c An contravention apprehended violence order made protection person d Unexplained serious injury person We now national legislation which requirement NDIS participants expanded scope per below dedicated 6 supporting function For an event be reported certain act needs happened connection provision supports services this includes death persons abuse or neglect unlawful sexual physical contact assault misconduct committed against presence person use restriction where not accordance authorisation state territory relation person authorised but behaviour support plan Not questioning intent just highlighting change scope lot complianc Training staff We also moved regulation around we onboard train supervise our staff (as largely employer discretion)

DISCLOSURE LOG

Providers reported that incident reporting involves the following responsibilities that are essential to meet the Commission’s requirements for registered providers: triage of all incident reports to ensure compliance with providers’ policies and mandatory requirements; responding to and reporting of incidents; follow up of incident reports including implementation of practice improvements identification trends development strategies address these trends incidence investigations incident reviews when required staff manager education In addition above registered providers who develop behaviour support plans or restrictive practices require provide monthly reports commission Submissions also reported management behavior support plan follows responsibility approval behaviour support in line restrictions reduction monitoring review of plans monthly report restrictive practice enhancement awareness best practice Sylvanvale provided case study highlight Quality Safeguarding work currently captured pricing arrangements They have more than similar cases running time Fred* adult living SIL Service has complex behaviours concern requires Behaviour Support Plan (BSP) includes several regulated restrictive practices routine chemical restraint use PRN medication Comprehensive BSP written November Specialist Practitioner attended location occasions observations met Site Manager read interpreted consolidated data allied health reports file Comprehensivesupportplan approved December 2019 Restrictive Practice Authorisation Panel chaired Senior Manager Practice Compliance since reviewed BSP independent Psychologist Regional Managers attend together Behaviour Support Practitioner/ Senior Manager Clinical Services customer with a Support Worker Prior panel convened submit RPA Panel tasks must be completed:

The Site Manager compiles an RPA Submission Pack takes hours RegionaManager another hour The pack checked by the Senior Manager Clinical Services incorrect will source correct information that goes Department Communities Justice DCJ Portal per pack Entered by Sylvanvale Admin participant restrictivpractices approx. [sic] Hours including Outcomes into Department Communities and Justice -DCJPortal for authorisation by RPAPanelMembers Authorization produced needs downloaded from DCJ Portal Sylvanvalle Customer File as well uploaded to NDIS Q&S Commission Portal one hour

DISCLOSURE LOG

OFFICIAL Quality and Safeguarding Costs

Subsequent to the panel process the Behaviour Support Practitioner needs to:

Upload the BSP Functional Behaviour Assessment identifies each individual Restrictive Practice Authorisation into the NDIS Q&S Commission Portal. The Authorised Reporting Officer Senior Manager Clinical Services has to report every single use of the Restrictive Practice at each Sylvanvale Outlet Location e.g SIL Community Participation each month [sic] take approx minutes). Reports need be run Admin each month gather data required any use PRN restrictive Practices (5 per customer pull data). Note While the Behaviour Support Practitioner can claim billable hours paid from Customers[sic] NDIS Plan their time regarding tasks other admin is cost doing business In July a month before provider planned support re engaging Specialist via Freds Support Coordinator who wrote plan left Sylvanvale Freds Support Coordinator located new external Specialist in August 2021 However this then withdrew service search continued until an appropriate provider engaged early October This took assessment develop new however, complex incomplete which meant practices authorised old expired practitioner requested update slow difficult contact During regulated practice had been part previously approved was: Required reported monthly by Authorised Reporting Officer (Restrictive will take approximately) Also as Reportable Incident Unauthorised Use within days expiring November reporting for Restrictive The contained different Restrictions must separately mins hour for Restrictive were weekly updated and it approved RPA Panel February For period BSP there total weeks separate reports URP to the NDIS Q&S Commission. All associated pre panel tasks outlined above repeated prior coming back to panel. The Submission Crosslinks Disability also argued costs incurred due managing reportable incidents restrictive practices communication with not accounted DSW Cost Model Crosslinks Quality Safeguarding Lead spends management on register organising leading meetings assisting managers when liaising therapists NDIS pays consultant $ per hour sit restrictive practice panel State requirements A of seven spend approx [sic hours reducing eliminating issues relevant General Manager spending approximate hours managing issues related restrictive does include daily

DISCLOSURE LOG

The submission by HelpingMinds similarly suggested there is significant requirement for reviewing incident reporting when providing psychosocial supports and that this is not factored into the DSW Cost Model.

Rocky Bay reported that the average time spent per investigation was 30 minutes but that many investigations took more work: Rocky Bay Community reported around 407 accidents in a six-month period ending June 2021, compared with about 391 full-year figures from earlier years; an average duration of thirty minutes per case. However some cases were significantly longer due to challenging customer behaviors or complex family situations where factors may affect home safety, taking up over five hours each on occasion.

DISCLOSURE LOG

OFFICIAL Quality and Safeguarding Costs

The data entry costs for reporting incidents to Commission were higher than necessary because limited technological solutions offered by the Commission made real-time reporting difficult due to manual technology limitations without sufficient funding. Members also raised concerns about reportable incidents being duplicately reported between state-based bodies such as coroners or police along with the Commission itself; they suggested streamlining information transfer among agencies could reduce duplication burden from providers while recommending a single incident-reporting system that would be interoperable across major provider management systems allowing easier import/export functionality which some members proposed should come directly through an investigation/reporting system provided by commission rather than third-party purchases.

DISCLOSURE LOG

However, submissions reported several challenges in the ability of providers to deliver adequate training and professional development. For example, The Queensland Alliance for Mental Health stated that it is not uncommon to recruit staff in the disability sector withe generic disability qualifications(for example,Certificate III Individual Support), or no formal qualifactions(particularlyin ruraland remote regions where thereis a lackof qualified applicants) annd thesestaff often require considerabletrainingto understandthe specific needs people receiving psychosocial supports withthis cost absorbedby provider. Qualified practitioners also requirerequire substantialtraingtomeet qualityandsafeguarding requirements Scheme.For example NeuroRehab AlliedHealth Networkreportedthat: In order meet NDIS PBS [Positive BehaviouralSupport] Capability Framework requirements ‘a core’ behaviour support practitioner we have calculated requires our registered psychologists between50-70 additional hours trainging includingour internal induction participation external workshops.Aside from costs attendance atexternal workshops therestabundant amount lost earnings outlay time takenfor practitonersto attendthese courses This ist addition standardprofessionaldevelopment requirementsthatpsychologists arerequired complete as part their professionalduties The submission Vision Australia similarly reportethat: Training developementcosts new service providers high they seldom possess vision spefic skillset commencement employment Once therapist role has been filled takes three months average provider to deveop specialist blindness and low vison skills Cost training development over $25, 000 per role given that theprovider is relatively unproductive during this time. The submission Rocky Bay reportedstruggledmeet current utilisation rate outlined inCost Model due need schedule enoughhours for trainings onquality safeguards alongside other essential activities team meetings incident reporting supervision The submission Ability First arguedutilisation ratesin CostModel do not allow sufficienttime non billable tasks such administration handover teem meetingandtraining. This consistent with modelling where theseactivities presumably fall withinother utilization category DSW model accounts just .4%standard intensity.This clearlyunattainable highlighted breakdown below detailsAbilityFirst’smodelling SIL services ‘other utilizaton’.

	Standard High Intensity

DISCLOSURE LOG

OFFICIAL Quality and Safeguarding Costs

| Client Reports | 23% | 3.*2% | Family/Stakeholder Engagement | 5.% | .7%. | | NDIS Coordinator Contact | .0.7|. %| | Liaising with Other Supports | %.0.| .4 | Total | *7“.7%

Disclosure Log

Greenacres Disability Services further suggested that:

Separating the funding of training from the funding of participant support will ensure that organisations provide adequate industry standard quality training to their workforce.

The Australian Services Union and Greenacres Disability Services also stated there should be independent industry bodies defining mandatory training requirements in accordance with NDIS Codes Practice Standards,

5.5 Supervision Submissions acknowledged need supervision. Mind Australia said: supervision allows staff discuss concerns issues experienced practitioner maintain wellbeing improve practice ultimately higher service participants. However many submissions workload supervisors managers increased because assist (and) workers adhere quality safeguarding requirements including standards reporting requirements. Many submissions reported current ratios utilisation assumptions do not allow sufficient education professional development upskilling new staff nor practices meet Commission’s quality safeguards standards.

DISCLOSURE LOG

OFFICIAL Quality and Safeguarding Costs

Mind employs SCHADS 5–6 workers to provide supervision to our staff… We have found that the requisite knowledge of NDIS systems, understanding of psychosocial theory and leadership capabilities to properly support staff is not found in applicants when we recruit below this level.

The submission from NeuroRehab Allied Health Network reported a particular supervision cost issue that arose from the Positive Behaviour Support Capability Framework, namely that registered behaviour support practitioners must receive regular supervision from someone rated above their own proficiency level (or at the same proficiency level if the clinician is ranked at the top tier of ‘specialist’). Within our service, we have just one clinician available over the next six months who we anticipate obtaining an endorsement above the ‘Core’ level of practitioner and able to supervise our eleven behaviour support practitioners. This supervisor will be unable to adequately cover all supervision needs due to volume of work As result; The service will be required to fund external supervisors (costs typically $200 per hour) for each supervised person). These supervisions are required both discussion clinical cases but also detailed review co-signing behavior support plans containing regulated restrictive practices. The submission Kyeema argued that supervision “severely under-funded”, suggested time being donated by providers as smaller organisation with fewer than participants lack economies scale meaning can spend less on overhead subsidise Supervision layer extent Our Supervisors mostly called Team Leaders organization cost us 12% revenue We paid <6% Revenue for this (7%) built-up costs Right now Kyeema donating $25K - $27k month NDIS in uncharged Supervision time That lost $300K annum would solve financial problems A number submissions suggested allowance should set higher rate attract retain qualified experienced staff at supervisory level For example Greenacres Disability Services suggests supervisors calculated Level SCHADS Award Many suggestions reviewed ratios utilisation assumptions provide workers per Supervisor more non-face-to face activities which allow sufficient education professional development upskilling Staff For example, Greenacres Disability Services suggest span control FTE and genU suggested a span headcount used model

Disclosure Log

Other issues

Some submissions drew comparisons with what they considered to be lower compliance requirements of unregistered providers, suggesting that cost differential places unregistered providers at advantage.

The submission from Allied Health Professions Australia indicated that this particularly true sole practitioners AHPA suggested should consider simplifying provider registration and auditing processes aim reducing costs complexity regulation pricing arrangements. The submission NeuroRehab Allied Health Network reported:

Undertaking NDIS certification provides participants higher level quality safety however effectively financially penalising providers undertake process. it also suggested some providers penalty placed registered providers terms associated registration ongoing dis-incentivises provider registration increases risk inadequate care provided participants Greenacres Disability Services described as incentivizing growth in Unregistered Providers cost quality safety suggest avoid these disincentives negative consequences not receive same funding as registered providers4 Australian Community Support Organisation warned: Unregistered organisations receive similar funding can negotiate a rate instances remain accountable no regulatory statutory oversight model is lacking fairness likely create two tiered system where there incentive for providers register it means continues situations where unregistered providers monitored leaving vulnerable dangerous situation inadequately being provided3 Some members working group were concerned lack differentiation between registered unregistered providers member wondered why any would choose Commission other than those delivering supports compulsory given subject price limit. Members reported aware allied health professionals decided re-register under the Commission due requirement auditin Members agreed well-functioning market advantageous reputation high quality, which could help with regard However they convinced current sophistication.

DISCLOSURE LOG

OFFICIAL Quality and Safeguarding Costs

Members of the working group were also concerned that the “unfair” competition between registered and unregistered providers was having other impacts on the sector. They argued, for example , t hat registered providers faced difficulties in matching th e pay rates offered b y negistered providers who could afford t o pay their staff higher r ates from their savings n a quality assurance costs . Members ot he w orking g roup considered thi s ti o be particularly problematic as registe red pr oviders we re often dealing with participants wh o had very complex support needs . Working Group members al so identified anumberof issues, including Continuity ol f Supportand Dutyol Care where thr equirementsot h Commission wer eno well aligned wi ththe Agency’s planning processesorwiththepricing arrangements.Memb ers reportedthatt he Commis ion appeared to expecttha tf isupporti st untenable thene provider should continueto provide it until anotherprovider i sn place even ifthr eparticipant ’s plan does not include sufficient fundingtosafelyprovidethesuppor tt ha nt he participantneeds.F ore xample,i ft heAgency has fundeda part icipantat1: but workplace safety requirements requirether esence of two workersthen there prov iderise expectedabsorb costsofthere second workerapparently indefinitely.Providers said this was particul arly probl ematicifaplanner found the additional supports required by teCommission tonot ber eason able and necessaryaspartochangecircumstances review.

Disclosure Log

OFFICIAL

Therapy Supports

The Review received a total of 122 submissions that spoke to pricing arrangements for Therapy Supports. Details of these submissions are at Appendix A.A working group comprising providers and other stakeholders met three times: December 3rd,

February 4th and March first in video-conference meetings held on Decembertenth,twenty twenty two February fourth twentytwo hundredtwentytwo,andMarchfirsttwentytwohundredtwenty-two respectively.The details about members can be foundinAppendix B.Key topics raised during consultations were:

Pricing Arrangements;
Training Registration; Comparisons To Other Schemes And Planning Issues. A submission coordinated Ability First Australia also received fromAbility WA,Benevolent Society,Cerebral Palsy Alliance CPL Coothinga North Queensland Montrose,Northcott Novita Rocky Bay Scope St Giles,SensesWA,therapy Focus,Xavier,Yooralla This group is estimated accountedfor twentieth percent NDIS therapy support market financial year That included detailed cost model reported Section eight five below.

Pricing Arrangements

Several submissions argued current price limits too low principal reason advanced increase wages because shortage therapists For example Jibber Jabber Allied Health reported median wage $90 thousand entry average staggering seventy-eight-thousand-eight-hundred-and-twentys. Increase driven largely by shortages hiring people qualifications NeuroRehab AlliedHealth Network similarly reported base salaries for allied health professionals increased annually junior team members seven to ten thousands senior members as a result of labour shortages Novitas particularly concerned inability compete with Government service providers Therapists

DISCLOSURE LOG

OFFICIAL Therapy Supports

The South Australian Government…is major competitor for allied health therapy staff and primary determinant in determining therapy salaries…. The Government pays higher salaries NDIS providers are able pay price cap. Working group members also argued that demand supply selected markets - particular provider reported thin market speech pathologists cochlear implant therapists metropolitan areas. Providers were concerned costs increasing because awards superannuation rates while price limits have been increased two years.^2 For example Therap Pro argued current base rate $134 calculated more half year ago Since then there has movement cost inputs primarily therapist salary on-costs which put pressure industry-wide business sustainability^3 Submissions working group members argue current price limits too low despite continuing impacts pandemic parents requesting therapy providers their office take RAT tests daily or higher cancellation as parents participants isolate try minimise contact Members noted price limits psychology lower than Society’s recommended rates particularly low clinical psychologists neuropsychologists forensic psychologists Also exercise physiologist should not atherapist services equally valuable equivalent level training subject GST IoT submission suggested price limit supports increase 210 per hour provide incentive recruit experienced clinically skilled practitioners competitive with government providers Submission NSW Health would total package close to$120,000 for physiotherapist around five (5) post-graduate experience. IoT suggests if hourly price is not increased over time they will lose skilled allied health practitioners public system who can provide higher salaries and working conditions In context personal training comparing NDIS price limits other schemes Extra Mile PT stated even after acknowledging exercise physiologists attract higher price limits requiring university degree qualifications professional registration the rate trainers ($58.)

DISCLOSURE LOG

than that of exercise physiologists ($$603457$. The submission stated at these rates personal trainers find unviable offer services through scheme discouraging providers participating.

The need attract and retain skilled therapists raised number times several discussions about pipeline future therapists Working group members noted university graduates do immediately have skills necessary work with NDIS participants Around months job training needed before graduate can effectively Scheme working group argued could achieve relatively low utilisation because train junior staff meet high compliance burden absorb undfunding participant plans Members reported utilise rates NDIs therapist rarely exceeded $%{to}%. In comparison private market therapy one working member noted cannot be leveraged same way as a private practitioner They argue private provider spread cost across larger base clients who each see private therapist less frequently Related point price limits account for supervision experienced staff Submission Living My Way similarly argues:

It essential new graduate early years therapists provided adequate training support more experienced therapist However current pricing make this difficult provide definitely not all organisations.

Working also argued there turnover in junior therapists did remain NDIS practitioners arguing limit pipeline future but increased search recruitment costs existing providers Without increase prices even established NDIS therapy would exit to private practice leading access familiar conditions Consultations consistently indicated preference per hour approach rather than consultation approach given reasons included: * Amount time service takes may highly variable depending client needs Tasks varying amounts complete home, the client overall situation. The therapist match delivery participan’s energy availability clinical need(s) example client 30 minute consults weeks whereas another require session hours Australian Podiatry Association argued that:

Disclosure Log

OFFICIAL Therapy Supports

A paediatric client may require a 60-minute consultation for therapy assessment and intervention compared to 30-minutes consulting personal care/hygiene for clients in intellectual disability.

Pricing Arrangements For Group Based Therapy

A number submissions also called reform group based pricing arrangements, such Australia Music Therapists Association argued:

current group price limits innovative service design delivery discounts per participant do not recognise additional administrative work groups should be recognised value they provide workload involved costed appropriately```

Dietitians Australia Speech Pathology Australia Mental Illness Fellowship all similarly argue that current price limit does account increased complexity time associated running sessions.

### Weekend Pricing
>To enable greater choice control grow market Australian Physiotherapy suggested introducing evening weekend pricing therapies They proposed evening week would drive new market offer more choices participants potentially increasing workforce allowing allied health professionals access childcare half day on weekends otherwise wouldn't have worked during week this bring skilled therapists from sector into NDIS The submission stated physiotherapist entitled reasonable appropriate times or rewarded working outside these times as other sections of Australian workforce are Increasing remuneration services award hours could incentive part-time casual physiotherapists those juggling commitments, providing services to NDIS This can provider opportunities expanding the NDIS market facilitating supply participation.

## Greater Certainty
>Consultations emphasised need certainty future price stability necessary practitioners continue perform space train support university graduates without changing existing business models.

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# Disclosure Log
The submission from Allied Health Professionals Association called on the Agency to provide greater certainty going forward by committing to:
* Increase the price limits for all allied health services so that they are consistent.
* Ensure the pricing arrangements and price limits are GST exclusive for all therapy support providers.
* Increase therapy support prices in line with inflation each financial year.
* Increase allied health price limits to consider after hours loading.
* Remove the current pricing cap on the provision of group supports, allowing these to be provided at a cost determined by the provider to enable them to be financially viable.`
## Compliance and administration
Working group members reported high compliance costs associated with the NDIS Quality and Safeguards Commission and related audits. They argued that for a small or individual practitioner there is little value-add to becoming a registered provider especially given AHPRA-regulated professions are accountable externally non-AHPRA regulated professions have strict codes conduct Lime Therapy suggested their submission does not factor reporting requirements Scheme under NDIS Quality Safety Commission `[T]he significant time burden associated NDIS reporting AT application review without requirement sign off recommendation prior payment Under other schemes therapist will apply funding [and when funded approved asked review` The submission NeuroRehab Allied Health Network also suggests Victoria Transport Accident Commission do require same level reporting accreditation standards NDIS Commission requires Submissions noted providers required undergo routine audit adhere changes made practice standards complete mandatory training modules which give rise costs factored into current pricing structure Australian Association Psychologists Inc.'s Submission stated costs working within such as $100 00 per year This account additional times energy produce policies procedures`

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# DISCLOSURE LOG
## OFFICIAL Therapy Supports
The submission from NeuroRehab Allied Health Network reported high levels of compliance cost.
For larger NDIS registered organisations maintaining registration through certification auditing incurs significant direct costs (~$10k pa in auditor fees and indirect labour costs), reducing revenue due reduced clinician availability; utilising agency funding has no benefit with just a small fraction using such services effectively.

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# Disclosure Log
The submission from Lime Therapy similarly argued that:
> NDIS set the expectation that administration costs would be at between 9 - 11% whereas all organisations have been reporting that it is more like the 17-18%. This hasn't changed given the additional worker orientation modules to be completed, mandatory reporting particularly under COVID19 conditions [NDIS registered providers must report both NDIA Commission and Department Health].
The submission Kurrajong also suggested continual changes scheme along with confusing pricing arrangements ambiguous guidelines increased administrative workload.
Members working group raised concern current arrangement does differentiate enough provider non face-to-face time differs professions Dieticians example spend larger portion performing activities such dietary analysis meal plan compared physiotherapists perform hands-on therapy Providers argue current pricing arrangements do not account differences For remote participants non-face-time reported critical resolving complex issues cannot resolved face-to-face prepare individualised resources these participants.
## Comparisons other schemes Consultations indicated strong demand for outside NDIS public funded schemes comparisons straightforward needed made care PROVIDERS ARGUED SOME OTHER SCHEMES ALLOWED MINUTE APPOINTMENT which insufficient length provide quality especially complex needs Participants COMPLEXITY OF ndis PARTICIPANTS MEANS THEY REQUIRE longer consultations higher level skill They ALSO Argued complexity of ndis participants INCREASED COSTS TRAINING new graduates LIMITED OPPORTUNITIES FOR PROVIDERS TAKE ADVANTAGE SCALE SERVICE DELIVERY
They argued some schemes Medicare Benefits Scheme rebate rather than fully funding support so can charge rates above specified price schedule recover gap It was also argued administration load on ndis participants significant private patients other schemes TRANSACTION costs associated being an ndis provider were also argued to be higher in other schemes providers other schemes NOT REQUIRED undergo QUALITY REVIEWS had more limited auditing processes Also argued ndis therapy support providers DEAL WITH MORE intermediaries Plan Managers Support Coordinators PROVIDERS POINT OUT THAT comparisions inappropriate case thin markets where ndis participants majority market such as therapy children or amputees Moreover they argued just because prices limits set by other schemes

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# DISCLOSURE LOG
## OFFICIAL Therapy Supports
were lower did not mean they were appropriate or sustainable—a working group member gave an example where Department of Veterans' Affairs rates for orthotists and prosthetists,
which are lower than NDIS price limits has resulted in orthotists and prosthetists leaving DVA scheme;
The context physiotherapy comparing NDIs price limit other schemes Australian Physiotherapy Association submission noted several reasons why these comparisons inappropriate They suggested that physiotherapists utilise less experienced staff with lower fees Additionally some schemes allow gap payments Finally fact physiotherapist operate low priced does imply providers think those fair reasonable.
In exercise physiology comparison NDIS price limits to other ESSA disagreed analysis reported NDIA Consultation paper claimed price limit under is higher average insurance schemes First Voice's submission stated expectations participants different from clients accessing services through Medicare, noting tended discrete time limited Submissions also stated require significantly more inter-professional multi-disciplinary liaison carer contact resource preparation risk management therapy accommodations/modifications assessment report preparation as well assistance advocacy The Australian Community Support Organisation further instances when therapists deal highly complex dual diagnostic participants supports specialised practitioners forensic psychologist required These specialisations do attract additional funding support under although government funded programs 6.4 Planning Issues Through consultations it was argued issues currently experienced by providers could be due insufficient hours included participant plan rather too low Working group members planners understand value allied health often making decisions without clinical training Suggested this results allocation of therapy hours plans working member provided example assistive technology being unfunded compared actual amount trials reports It was noted some will perform and bill full amount trial reports already underway

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# DISCLOSURE LOG

Providers noted there was a lack of information and clarity around how long some services such as quality reports may take that participants were often unwilling to sign off.

Providers also noted insufficient funding impacts non-face-to-face time billed can be.

Working group members suggested more training guidance Plan Managers particularly in relation what charged would save administration therapists explain different supports charged spent having.

time saved.

Members discussed therapy categorised they noted instances certain sessions relate strictly building capacity but are still important person maintain their standard living lose capacity example wound care However other members noted these items remain Core lead plans being funded with expectation will be through budget.

Consultations spoke insufficent funding travel In discussion working group noted forms early childhood or exposure effective participant homes particular locations require provider travel arrangements multiple rural/remote clinic difficult especially if drop out fees need renegotiated across remaining participants Working group noted providers providing services thin markets needed further even metropolitan areas unable pass on recover costs lot unbillable much travel.

These arguments supported submissions received First Voice said restriction charge 30 minutes challenging for any service, specialist where number limited providers travelling distances metro areas Australian Music Therapy Association stated members end up one hour return appointment metropolis whilst NDIS Price Guide states maximum amount claim MMM1-3 is area $9.31152 (48 hours @ $193) designed serve a participant weekly allowing holidays With provider able allocate to session the participant reduced face-to-face service provision impacts outcomes participants Down Syndrome Australia noted that:

...a therapy budget of ($9.311$ per week allows holiday With provider allocation time the participant reduced over period This reduction in face-to-face service provision impacts The submission Vision Australia noted its:...
members have found insufficient for providers According Modified Monash Model can claim minutes travel time metro but there are many clients whom

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# Disclosure Log
## OFFICIAL Therapy Supports
travel will take significantly longer than this, even within capital cities.
One provider calculated that 
every NDIS service delivered,
average non-billable travel time
cost $950 funded Vision Australia^1^
### Major Therapy Provider Submission
A major joint submission pricing arrangements therapy supports received from Ability FirstAbility WA Benevolent Society Cerebral Palsy Alliance Cootharinga North Queensland CPL Montrose Northcott Novita Rocky Bay Scope St Giles Senses WATherapy Focus Xavier Yooralla^2^
these providers together account about %NDIS expenditure on therapy
supports Their joint submission identified following shared characteristics these organisations:
- They operate at scale often State-wide and in some cases a National footprint.
They recruit train employ large workforces allied health professionals fact around new staff (new graduates or workers sector) are employed trained group each year.
The have robust clinical governance systems all levels organisation – Board.
operate with significant physical IT infrastructures important market level.
support staff develop skills high standard number specialisations required support people disability.
have particular focus deep expertise working multiple complex disabilities.
as part their submission these engaged Deloitte Access Economics construct cost model for therapy based detailed analysis financial performance various providers. The stated Cost Model shows actual of delivery 2021 was per hour psychology other disciplines [Occupational Theraphy, Physiotherapy Speech Pathology Social Work Psychology]. When disaggregated by regional result metropolitan regions was $2438 per hour psychological staff $19704 others Allied Health Staff This demonstrates majority surveyed operated break-even against current NDIS prices caps More detail the costing undertaken Deloitte Access Economics major therapy providers shown chart Exhibit EDeloitte report to major therapy providers.

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# Disclosure Log
## Exhibit 3: Deloitte Access Economics Estimate Cost per Hour of Allied Health Services Under NDIS
![](https://example.com/image.png)

The joint submission from major therapy providers also addressed the issue of appropriate benchmarking in relation to NDIS prices.
The submissions argued that comparisons are flawed because they assume:
- The cost structures and service models used vary significantly between jurisdictions due primarily but not exclusively as a result of differences arising out of different legislative frameworks governing each jurisdiction's respective scheme.

Working within these social support systems can be challenging work often requiring approaches which do not fit with more traditional rehabilitation schemes such those found elsewhere,
together with other insurance schemes, etc.,
as well as strategies for maximising participation choice control over people who have complex needs or special requirements.
This difference is fundamentally one based on medical model versus therapeutic support services provided through various means including accident recovery schemes where focus tends towards long-term habilitation rather than short term treatment.

**Recommendations:**
* Don't reduce current price cap;
based upon findings contained herein it has been recommended this group proposes maintaining at least existing levels using blended single pricing caps.
* Reintroduce price indexing for therapy supports immediately increasing costs by an amount sufficient enough so as make up any shortfall experienced during previous years.
* Broaden definition billable time reflect true productivity associated directly related specifically with provision thereof.
* Work toward removal capping mechanism applied broadly across all markets medium term if possible otherwise sooner. We propose pilot testing application in selected areas (e.g capital metros).
* Consider Agency approach to benchmarking prices against others considering appropriateness jurisdictions involved further research into underlying cost structures.

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# DISCLOSURE LOG
## OFFICIAL Therapy Supports
services delivered under each jurisdiction before confirming the pricing arrangements in other jurisdictions are appropriate to benchmark.
* Work with this group to better understand the cost of services. This group invites that agency work together and develop mature costing models help identify true costs therapy supports will ensure agencies can price quality service provide meaningful basis benchmarks private providers comparable funding regimes.
* Provide certainty future NDIA should commit long-term pricing framework Providers need make decisions around services infrastructure based forecasts next years Commitment road map give participants clarity about environment confidence invest include commitment annual indexation Pricing.
* Provide adequate notice changes The NDIA must provide ample notice therapists support providers what pricing changes effect July 2022 Providers significant investment systems staff training communication customers every time change made pricing framework take months prepare Notice regarding changes for budget business planning cycles service providers.

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# Nursing Supports

A total of seven (η) submissions were received about the pricing arrangements for nursing supports in response to the Consultation Paper [see Appendix A]. A working group of providers and other stakeholders was also established.

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# DISCLOSURE LOG
## OFFICIAL Nursing Supports
The treatment of wounds can leave nurses out-of-pocket due to consumables needed during initial assessments.
Members of the working group were concerned that nursing price limits had remained unchanged over two years despite increased service costs. Different members suggested varying increases from a $35% increase matching union requests up to parity with Clinical Nurse Consultants and allied health professionals in disability services; they noted similar salaries are paid when experienced clinical nurse consultants work alongside these professions within disabilities sectors provider submissions also recommended aligning nursing support prices with those provided similarly by Allied Health Professionals.

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# Disclosure Log
The Continence Foundation of Australia recommended that:
> The fee for service for an expert nurse including a Contience Nurse Specialist working at the level 
of Clinical Nurse Consultant providing continence assessment should be same as teh fee 
service for an allied health professional episodic therapy rate.
The submission from Royal District Nursing Service South Austria stated Scheme's price limits are significantly lower both their Fee For Services rates and they currently have with various funders including SA Health Commonwealth Home Support Program DVA Community Nursing Program.

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# DISCLOSURE LOG
## OFFICIAL Nursing Supports
...the amount of travel that can be claimed to facilitate specialist continence is limited to one hour fo...
### Planning Issues
A number of submissions reported cases where insufficient funding was included in plans to meet clinical need.
The submission from At Home Care stated:
> ...The NDIS fund one hour for a catheter change which doesn't take into consideration travel time to/from client's home....Travel time is not supported for certain clients - clients are knocked back and do not have choice if there is only provider i their local area.`
Members of working group argued planners sometimes do not build enough hours into plan. They provided examples they considered plann had not inclu:•Sufficient funding defined task – example, providers report instances when planners allowed four hours contine assessments wh providers consider these generally require around six hours.•Funding nurses provide training or additional support workers • Funding services drive better long term outcomes exampel planner refused appropriate wrap-around supports required ensure high quality diabetes management• Funderg handovers clinically necessary For 24-hour suppoers providere argue participants should receive $5$ hours fuding also cover handover• Fundng necessa amoun travel This means participant cannot receive the cliniy necesary amount treatment as they need spend some treatmen funds on travel or receive no suport at all Members workin grp were concernd that planners may understand skills scope practice different levels nures so may not pr...

1 Continence Foundation Australia Submission S06 p.
2 Continence Foundat Aust Submision S06 p .
3 At Home Care Pty Ltd submission s054 P.

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# DISCLOSURE LOG
The submission from the Continence Foundation of Australia stated that greater access to both specialist comprehensive continence health assessments and capacity building supports are necessary to deliver improved outcomes for NDIS participants.
In its submission, CFA suggests the Agency should actively recognise:
- The need for continence services can deliver contemporary evidence-based effective continence assessment alternatives lower quality ensure stewardship market equitable access these services.
The submission also reported following major policy change include disability-related continence in NDLS 4060K participants reassessment light change highly unlikely affected had appropriate access NCSS comprehensive continuum assessments.
The Royal District Nursing Service South argued current planning arrangements restrict participant choice control increase scheme costs overall where nursing funding ceases nurses replaced support workers medication administration minimum visit time hours whereas Royal District Nursing Service virtual service able charge rate increments minutes.

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# Plan Management Supports

A total of 69 submissions about the pricing arrangements for plan management.
Details are at Appendix A and in detail provided below:
- **Disability Intermediaries Australia Submission**
- Role & Value of Plan Managers;
- Pricing Arrangements; Indexation,
Other Issues.

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# DISCLOSURE LOG
The DIA submission argued that registered Plan Managers represented value-for-money for participants and Scheme.
In 2020–21 RPMPs managed approximately $1243bn committed funds in Scheme schemes.
The same period RPPMs billed scheme $37m services or just %of funds under management or%funds claimed.
to compare contrast adjacent sectors, DIA's research indicates that in 2020-21:
* Financial Services sector operated at around ;
* Administration Support Services sector at around;
* Health Care Social Assistance sector (private) at around;,
* Administration & Insurancsector public at aroundand
Professional Services sector operated at around .'
The DIA submission reported that54%the indicated they has made a profitin with further indicating that they had broken even in Some responses to survey by large Plan Managereported surplus compared medium PlanManagers small PlanManagers At timeonly of responses surveyed by largePlan managersreported losscomparedmedium PlanManagerssmall PlanManagers The found no statistical differences betweenfor-profitprofit-purpose not-for-profit PlanManagers With respect size profits being madeby the DIA submitted reported average EBITDA as percentage total costs across respondents was%,with achieved above%.The also reported "large" Plan Managers higher returns onaverage than smaller Plan Managers.The average EBIDTA for "large" Plan Managerswas ,compariedto andFor almost two-thirds(64%) of "large" Plan Managers anEBITDAMorethan in,,compared to %for "medium" PlanManagersand For small PlanManagers againfound no statistically differentbetweenfor-profitsmall-plan-managers.
With industrial conditions, the DIA survey found only 29%ofrespondents employed participant facing staff under SCHADS Award noting share increased last months.35% some respondents supervised their employing staff under SCHADSAward uplast18months
With allowances,DIAsurveyedthat:

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# DISCLOSURE LOG
## OFFICIAL Plan Management Supports
...35%oftheorganisationspaidallowancesorfringebenefitswilst59%answeredtheydidnot.
6%dosurvey'srespondentsdiddotprovideananswer.<sup>\<sub><sup>
With respecttoutilisation,theDIA surveyfoundthat...
timeundertakingbillablework)<between75and85%. ... <sup>\<sub><sup>
Wherewithrespectoverheadsthe DIA surveyonfoun anaverage reported overhead (as a share direct costs) o f(79%) with medianofof(67%).
### Disability Intermediaries Australia’s Proposed Cost Model
DIAs submission included cost model for fully loaded hourlycosts thatPlan Managers incur when employing participant facing staff(seeeXhibit). The structure DIACostModelwas based on NDISDisability Support WorkerCost ModelfollowedbyAgency to set price limits many core supports.DIAreports itsassumptions werebasedon results ofitsurveys other information collected directly from providers and publicly availableinformation.It further reports the ‘most standard’ informationavailable was utilised.4
#### EXHIBIT 5: DISABILITY INTERMEDIARIES AUSTRALIA COST MODEL FOR PLAN MANAGEMENT
| **DIA Cost Model per hour worked** | **Cumulative Priceperhourworked** | **RationaleforDIAprice** |
|---|
| Base Pay $34,0$ | SCHADS pay point / week | No shift loadings 
- Annual leave $12$ |  days year |  day year 
- Personalleave $18$ | - Public holidays $18$ |  day year 
Employee costs 
Superannuation $4\<sub><sup> Added at statutory minimum Workers Compensation premiums found wages salaries Supervision $594$ SCHA DSDpaypoint/week ratio supervisors to staff Utilisation $876$ rest time breaks training activities Overheads $10^89$ Rent IT Audit compliance Marketing Other Margin $3^{+}7$ shareofothercosts

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# Disclosure Log
## Role and Value of Plan Managers
Members of the working group emphasised that members made submissions about how much more involved plan managers are in processing invoices compared to other roles.
They stated these include education, guidance capacity building customer service; they also argued educating participants families budget issues helps ensure plans work efficiently effectively supporting Scheme sustainability Members worked agency prevent fraud financial rigour billing payments.
The scope varied needs participant defined role manager as being "financial intermediary" participant advises finances helping them understand decisions flow consequences spending allocated funds contrasted with Support Coordinators who were “service intermediaries”
Plan Managere often first point call or support available during times change uncertainty found took long complex seek information assistance from Agency Members said Plan Managersthe“only ones will pick up phone picked slack ways assist participants crisis changing circumstances.”

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# DISCLOSURE LOG
## OFFICIAL Plan Management Supports
setting a monthly price for this service there is an expectation that Plan Managers will engage some participants for less than $\text{14}$. and others for more than \$0.
First2Care emphasised what they considered to be the inadequacy of the current price limit for the monthly fee by arguing that the \( 	ext{ͥ}{	extstyle {1}}_{	ext{{week}}}^{+}	ext{}=	ext{}rac{	ext{{7}}}{	ext{{24}},}$ over four-week period which translates approximately hour's wages of Level SCHADs Award employee They reported:
...It takes one per week participant, it work employees qualified beyond level Award deliver high quality plan management The monthly rate of \( 	ext{ͥ}_{	ext{{month}}}^+	ext{}=\	ext{{189},}\) for Plan Manager dismal compensation services we provide especially in comparison other types providers For example represents  minute appointment with allied health worker or min psychologist A number submissions argued that Plan Managers undertake additional work processing invoices including: - Providing defacto support coordination role where participant does not have support coordination their plan Participants do know Local Area Coordinator good rapport them Educating fielding enquiries from participants about use funds plans particularly if Participant does Support Coordinator doesn't understand information provided NDIA Most participants download consume NDIS Price Guides without this being presented digestible format is Plan Manager must convey changes plain-English participants Living Way stated there unfunded costs seeking information Agency interpretation pricing arrangements communicating to participants When a participant sends an invoice clearly within NDIS Pricing arrangements time liaise with participants service provider attempts contact NDIS consistent answers This Monthly Processing Fee Disability Trust pointed out higher than they needed because increased associated processing invoices PDF paper-based versions key internal systems payment reimbursement suggested NDIS registered providers already claim the portal should option submitting claims Portal would enable Plan Managers approve these claims

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# DISCLOSURE LOG

A number of submissions also highlighted costs that they incur as a result of mistakes made 
by planners.	For example,	Action	On	disability within Ethnic Communities stated that

> NDIS plans are frequently approved with pricing which is not in line with updated NDIS prices.ADEC has received planswhich havestated Plan Management fees wherewere years old.Currently approximatelyone-thirdof ADECPPlanManagement clientsarenot billed atthe current rateas participants'plans aroutlinedwith an olderrate... providers must coverthegap and charge thparticpantsat alower rate.The amount administration providermust go through to rectifythis issue isnot proportionate, it unfairto rejecta request for service from aparticipant simply because NDIA madan administrative error on participant's plan.

Submissions stated ensuring fundingallocated correctlyand inlineNDIS price limits necessaryforproviders be adequately compensated services provision Not doing so mayresult thinning margins disincetivise providers remaininprovider space.
Several submission identified information technology particular area increasing cost for Plan Managers The DAIsubmission reportedtechnology second largest overheadcosts Planners accounted 16.8% totaloverheads following administrativeto407%.D arguedpricing arrangements need give greater consideration technolog overhaeds ifPlannerManagers Agency benefit streamlining efficiency gains available technology.
The submissions Action DisabilitywithinEthnicCommunities similarly state quality IT system required PlannerManager high functioning effective but acquiring suchtechnoloy substantial cost especially smallmedium planners.	A low end Plan Managemen software can $15,	$35	This large upfront costs new providers Without this provider find difficult grow process workload monitorhigh number plansPlan management different other NDISservices where complexITsystem require highfunctioning program This must factored into planmanagement rates.
In regard Connect Plan Managementreported that the of IT had increased above inflation in part due disruptions to:
global supply chains shortages semiconductors absence skilled worker immigration Australia during COVID-19 pandemic.
Members working group also felt currentprice limit monthly fee inadequate and identify areas which managers facing cost pressures unaccounted pricingarrangements including called address inefficiencies elsewhere Scheme.

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# DISCLOSURE LOG
## OFFICIAL Plan Management Supports
One member of the working group stated that there were lots participants within Scheme see 'Plan Managers' all they've got'. They noted that %54% their Participants have support coordination Another member said now doing role Local Area Coordinator and plans are adequately funded do task Argued funding should be redirected Plans Managerto support responsibility Further stated agency hold Areas Coordinators accountable gap in their role expectation Local Areas Coordinators would continue sustain relationship with throughout tenure plan renewal participant Members stressed faced rising number overspends unfunded work One team grown three times over rate growth order effectively support participants Solution proposed incorporate few extra hours accommodate local areas coordinators.
Members also reported often spend unfunded time resolving considered to errors or capacity issues" Members sometimes need diagnose service bookings made Agency communicate issue Agency resolve Members expressed view driving absent capacity issues Major concern members working group implication costs perceived increasing expectations Agency checking invoice evidence, preventing fraud compliance when participants exceed allocated funds Member summarised this saying:
there is disparity between what funded [within scheme] how used flexibly versus who liable for this.
Members raised challenges associated liabilities making claim if Plan Managers ultimately held responsible overspent funds within plans. One client 89% clients spending beyond means plans Another pointed open-ended liability around agreements able sign (without involvement by Plan Manager) infinite amount of money for an infinite amount Money Members noted unfair on taking responsibility noting tax accountants not responsible paying debt Clients Members queried why Plan Managers different regard Members emphasised that managers control oversee all decision-making processes In summary member the working group said unsure Agency's expectations regarding checking invoice evidence and preventing fraud They called clear statement issued agency detailing responsibilities managers face help mitigate confusion
Members emphasized particularly disadvantaged carrying role some area now seems expect them current arrangements do provide visibility participant plan As result Plans Managernot have sufficient clarity funding limitations budgets allocation managed supports argued causes

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# DISCLOSURE LOG

numerous administrative and payment problems and weakens relationships with providers 
and participants when funding is suddenly exhausted,
to services delivered in good faith
delivered according with service agreement participant.
members were united their desire be given full visibility plans perform role within remit.They argued that document Plan Managers are currently provided does provide sufficient information funds included plan.Plan managers expected ensure funds spent alignment intent participant's but cannot do as they access reasons planner has included funds so know what intention participant’s plan instances where more detailed additional contexts figures being recorded.This available at agency back-end portal.Members stressed lack correlation between information a manager can compliance team deep problematically.A sub-issue arose discussion challenges faced liaising providerAgency.Membe pointed five main:
- **Invoicing:** Members stated Agency payments teams refuse direct communication from provider managed support,Plan Manager step make those claims instead Provider Specifically, Plan Manager claim invoice for service also disperse funds.Members raised hesitancy to approach Agency leads increase calls fielded workforce Member noted 40% of team not touching invoices spending time responding queries should handled Agency.
- **Manual Claims:** Members difficulty processing manual claims Payments Team Additional burden comes completing manually by having detail every item needs claimed.
- **Timeliness Communication:** Members raise lack timeliness Agency noting months take stop paying after reports fraud As result this lack timeliness Plan Managereported often have recuperate lost funds Participant
- **Change Circumstances:** Members note difficulties arise when providers behave changes approved bill services without conducting appropriate checks increased level service been approved. Members felt clearer guidance needed given providers operate any chance circumstance request possibility refused mitigate issue.Members pointed out these issues exacerbated fact neither providers nor Plan Managers informed Agency plans altered change circumstances or other reason.
- **Out Scope Work Including After Death:** Members reported that Plan managers perform work current pricing arrangement but believe expected suggested recommended participant's death.

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# DISCLOSURE LOG
## OFFICIAL Plan Management Supports
Agency.
For example,
when participant dies,
Plan Managers are expected
to tie up loose ends and resolve unpaid invoices services such lawn mowing gardening no-show fees that have been incurred before providers were notified participants death though they permitted charge monthly fee after participant has died Members working group stressed all these issues both directly increased costs being a Plan Manager risk raised which in turn raises cost They some main reasons why current price limits inadequate Another pressure identified submission Spinal Cord Australia difficulty faced attracting retaining suitable workforce holds professional qualifications Scheme management The challenge sourcing appropriately qualified labour further supported Connect Plan Management who stated there: ...has widespread commentary media regarding employers generally specifically certain sectors found continue difficult attract retain staff This confirmed anecdotally from own experience conversations other NDIS providers The submissions from Disability Intermediaries Australia Connect Plan Management Services also raised concern about payroll tax not addressed pricing arrangements for Plan Managers (and other supports) Both recognising payrolls do accumulate size charity status but argued pertinent almost larger providers plan management services Submissions proposed Agency undertake analysis issue Monthly Fee Structure A number of concerned one-size-fits-all nature price limit monthy fee They said flat monthly insufficient cover workload transactions associated with large plans particularly where participant receives many different providers Many proposals restructuring reflect level work undertaken complex plans Avivo reported present providers receive same monthly fee $5k bi-monthly invoice as we do funding over $100, 000 across
---

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# DISCLOSURE LOG

In addition, submissions stated that a plan which receives allied health supports has far fewer invoices compared to clients receiving daily and consumables/assistive technology amongst other supports.
However,
as Action On Disability within Ethnic Communities Stated:

> A participant who only had Consumable section in their NDIS Plan pays same annual rate for plan management as participants with entire plans managed by PMs.
Dennluc8 Pty Ltd reported ratio between number of lines per participant varies up-to-5% resulting significant differences effort smaller/larger participant plans whilst receiving monthly fee.
Living Right argued current price limit on monthly fees does not recognize need provide additional support complex needs or disadvantaged/Culturally/Linguistically Diverse participants Their submission said insufficient when supporting culturally linguistically diverse/disadvantaged backgrounds higher support needs:

Participants from these background generally do no have reasonable level numeracy literacy skills understand plan statements negotiate provider agreements budget In addition due transience Northern Territory population changes Local Area Coordinators participants inevitably seek further support us...
many our participants access emails feel empowered enough ring NDIA directly for supports intensifies way we are required communicate them participate Often requested participants negotiate service agreements oversee the plan budget manage act intermediary providers enquiries especially unregistered providers who don't understand guidelines or limits We also required regular phone updates about spending funding balances For reasons believe inadequate as plan management goes over standard processing payment claims issuing financial reports to participants.
A number submissions proposed Agency should consider replacing existing flat monthly fee pricing system proportionate total value participants' plan reflect workload larger numbers processed

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# DISCLOSURE LOG
## OFFICIAL Plan Management Supports
Invoices, or took into account the complexity of participant’s plan; complex plans require more effort by Plan Managers and higher number supports providers.
Members Working Group acknowledged workload varied significantly but did balance support differential fee structure they considered issue manager manage within their overall budget any such would need very complex open abuse disagreement Establishment Fee A submissions stated current establishment insufficient onboard new participants Disabilities Intermediaries Australia proposed price limit Establishment should be increased from its level $232 .

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# Capacity Building & Training
With respect to the "Capacity Building and Training in Plan and Financial Management" support item Spinal Cord Injuries Australia stated that major difficulty participants:
... rarely have access CB training plan management supports ... price guide.
Members working group agreed funding very rarely included plans above set-up monthly fee costs considered unfortunate greater use would allow Plan Managers vary their offering depending participant needs so standard monthly fee could cover service additional capacity building separately One option might be allowing fungibility between core budget participants choose spend some desired DIA submission also proposed should consider increasing hourly limit $683 per hour linking amount Level future pricing changes.

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# DISCLOSURE LOG
## OFFICIAL Plan Management Supports
appropriate price and skills.
Members added that macroeconomic drivers – employment,
unemployment, wages growth should be factored into indexation algorithm.
The Working Group also raised issues how limits were currently indexed within plans They stated that rolled over do have prices increased new applicable time period.
They identified still had plan management supports Members Were concerned about implications cash flows trend towards multi-year plans Again because item in providers would forced operate fixed increasingly out date limit length 
### Other Issues
#### Shared Management
The submission from Avivo showed charts Consult Paper disability sector steady decline shared management stagnation self-management The further submitted NDIS funding policy inability participants opt formally Share Manage lack guidance on how participants can work towards self-management reported planners often reject requests for fees Shared Management Advisor or payroll services because not clearly provided catalogue.
This highlights opportunity to support participants way works safety net present Under current NDIS management there is no formal option share manage options appear help navigate engaging managing staff There appears assumption bear full responsibility tasks involved engaging supports unrealistic comparable other schemes globally Participants may choose engage own supports but choose take such as due capacity risk appetite personal preferences 1 Avivo proposed Agency consider broadening available under plan management incorporate advisory payrolling services options participant's self-manage
## Claims Point of Support System
A number submissions acknowledged potential efficiency benefits implementing the new CPOS system However they also raised concerns impact it will affect costs role Plan Managers and participants.2

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# DISCLOSURE LOG
Other submissions were concerned that the introduction of CPOS might have unintended consequences for Scheme sustainability and integrity.
First2Care argued Plan Managers provide oversight into claims made ensure aligns service agreements instantaneous system:
lead overspending budget utilisation purchasing supports do participants' stated items goals.
First Care proposes careful consideration how will impact visibility participant budgets consequent role active fraud prevention alignment spending with participant goals.
The submission Avivo similarly concerns CPOS replace some or all current responsibilities Plan Managers such as replacing their handling payments therefore potentially restricting capacity real-time monitoring.
Connect Plan Management's concern potential escalate technology costs managers.
Avivo proposed should offer option rather replacement plan management urged agency recognise services beyond processing invoices supporting participants work towards maintain self-management several situations where a participant may value another option including engaging own employees wages tax super can't be paid using CPOS making payments to contractors who don’t facilities providers did not Statement Supplier; unregistered if linked registration status.
Members Working Group also concerned about challenges faced adapting smaller organisations lack digital infrastructure providing full array needed subsidising back-office whereas larger invested heavily in technology drive efficiencies financial checks One member Working Group was concerned heighten information flows between participants, providers Agency particularly small organizations ability invest. Stated importance addressing this challenge when rolls out CPOS need acknowledge different platforms.

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# DISCLOSURE LOG
## OFFICIAL Plan Management Supports
Another Member raised the inherent costs incurred by providers whenever the Agency changes systems.
They noted that some providers are rolling out the previous API system despite it being formally launched in two years ago.It was also noted that the sector's investment in technology was static.
### Role Clarity and Independence Members of the Working Group felt that a major difficulty facing Plan Managers was that the roles of Support Coordinators and Plan Managers were blurred and poorly defined.They considered that this lack of role clarity inhibited participants from clearly understanding the differences in services between Plan Managers and Support Coordinatorsandthe associated fees.This concernwasalsoraisedinanumberofsubmissions.For example,thesubmissionfromActiononDisabilitywithinEthnicCommunitiesstatedthat:...PlanManagementPrinciplevergesontosupportcoordinationanda timeconsumingduty.A dutywhichthecurrentpricingarrangementdoesnotfactorin.Greaterclarityisrequiredfor classifyingtheroleofaPlanManagerifitistoincludegreaterparticipantinteraction therate mustreflectthis.^1Members of theWorkingGroupalsoreconsideredthat greater clariﬁcation onrole deﬁnitions will allowparticipants to better understand theseervicesaplan Managerprovidesandan mayallow participants toencreasingly leverage aplan Managercapacitybuildingandretraining inp lan ﬁ nancialmanagementservices.Thisiswould alloowparticpants toe increasingunderstand how anda ndwhere their money is used an mightencourage particpants too have more control overtheir plansan payments. A numbero f submissions also recognised th at conﬂicts o finterest could arise when Pl a nManagers,Su pportCo ordinato rs,anddisabilit ysupport providers were not independent each other^2 Theywere concerned that parti cipantsmaybes ubjectto'client capture', whereby asingle provider signs aparticipant withtheir complete funding signedt ot he oneprovider.Thisallowsasingle pro vidertot fullyexhaustthes budgetoa participantwithone organisation,maximisingtheir individualrevenue ata potential detrimenttoparticipants The submissionfromCPS(Choice Plan Services)statedthatsupporting and enforcing independence ofPl amangers, Support Coordinatorsand disability supportprovidersis vital ensure particip ants arenotbeing taken advantageofandalocked intoplans do no provide themw ith appropriate supports.

> I know from talking t oparticpant sthat they often feelthattheyare unable to engage wit hother servicesornew service s mighth become available astheyhavesigned 10%off thei rfunding
tooneserviceprovid er.Somet imes theseparticpants(youngchildren )a reputonto waiting listsfor ser vice suchasspeech therapy (there is currently4-6 monthwait for speechtherapy inthen South west), an d during this wait time ,theyfeelt hattheycannot sourceanother prov iderast heyhavealreadysigned a serv ice agreement.^3

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# DISCLOSURE LOG
Some of the disability support providers on the Working Group identified examples of biases among Plan Managers, including: Plan Managers refusing to accept invoices from particular providers; Plan Managers have a relationship with support workers (for example, spousal relationships) and this resulting in preferential treatment; and the situation where a Plan Manager is also a participant's SIL provider, and hence by rejecting invoices from other providers, there is more money drawn down on for the SIL services.
One member of the Working Group suggested that reporting the bad practices of Plan Managers and Support Coordinators to the Agency or Commission had not led to satisfactory outcomes. They said when they reported Plan Managers to the Agency, they were told it does get involved in Plan Manager disputes. Some providers experienced consequences such as losing participants due to reporting these individuals. It suggests legislation lacks sufficient processes regarding de-registering those acting outside Scheme spirit.

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# Agency.

## Insurance
### Disability
#### National
##### Released information:
The act that was

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# DISCLOSURE LOG

Coordinators reported a surplus in 2020–21 compared to 42% for "medium" Support Coordinators and 45% of “small” Support Coordinators. Around one-fifth of responses to the survey by large“and medium”Support Coordinatorsreportedalossinin2020-21comparedto7%for small

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# Disclosure Log
## Official Support Coordination
### Disability Intermediaries Australia’s Proposed Cost Model
Exhibit 6 summarises the findings comparing NDIA’s current price limits for support coordination with those put forward by DIA based on their survey results.
As with the NDIA's DSW cost model,
the DIA's cost model for Support Coordinators builds from a base pay rate adding incremental hourly costs that are incurred in the delivery of the support coordination supports.DIA's proposal for each support coordination level shown Exhibitions7to9.

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# DISCLOSURE LOG

| DIA Cost Model | Cumulative Price | Rationale for DIA price |
|-|-|-|
| Employee costs &ndash; Superannuation $47&cent;$ &ndash; Workers' comp$05&cent;&ndash;- Allowances$063&cent;Supervision Utilisation Overheads Staff Retention and Turnover Staff Retention CostStaff Turnover Cost Margin Total | $54<sup>..</sup>$|$ Itwasfoundthatwell over a halfof respondents pay allowances with vehicle ($1289)and miscellaneous($300representingthecostto employers.The'span controlfor Level: Coordinationofof Supports workers is set at aratio o f one Supervisor overseeing fivehalf (FTE):CoordinationofofSupportsworkers.Participant facing SCs spends their time delivering NDIS supports restoftime in on breaks, training,and other activitiesOverheadsa 20% of directcosts(i.e.,the above costssurvey found that themedian cost forthereplacement Support Coordinators was $4692 per annum.$1.20$2.<sup>. </sup>&nbsp;<sup>.</sup>| $110<sub><sup></sup>			r
			Exhibit 9 DISABILITY INTERMEDIARIES AUSTRALIA COST MODEL FOR SUPPORT COORDINATION LEVEL 3| DIACost ModelCumulative PriceRationale forDIA priceBase PayLeave Entitlementsand Annual leave Personalleave Public holidays Employee costs &ndash; Superannuation&ndash;- Workers' compAllowances Supervision Utilisation Overheads Staff Retention and TurnoverStaff Retention CostStaffTurnover Cost Margin Total | $76<sup>..</sup>$|$ SCHADS8perhourNo shift loadings152hrs76 hrs76 hrs$86<sup>...</sup>$|

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# Disclosure Log
## OFFICIAL Support Coordination
### Role and Value of Support Coordinators

**MR25/01967 FOI 24/25-2242**

* **Efficiency:** support coordination when delivered effectively creates efficiencies can save money NDIS participants.
* **Capacity building:***support coordination effective build participant capacity some cases long-term.*
* *Relationships networks:* support coordination deliver effectively builds relationships within communities assists participants navigate plans*

Stakeholders noted definition supports unclear difficult distinguish Plan Management supports Several submissions state roles Supports Coordinators Managers blurred poorly defined One provider drew comparison between Plan Management support stating:

>Plan Management Principle verges onto support coordination time consuming duty current pricing arrangement does not factor in Greater clarity needed classifying role Manager if greater interaction rate must reflect this`

Consultations revealed scope activities undertaken expectations varied metropolitan regional rural areas Stakeholders generally supported need establish quality professional standards practice to registration audit structures stakeholders also spoke clearly define different levels support coordination Member stated distinction "absolutely necessary moment because Participants are specialised" Another Member said organisation has specialist skill set managing complex case meetings clinical mental health services This Member further noted such supports were outside Level service The Working Group discussed Specialist support coordination more just coordinating large number supporting Participant particular needs Rather involved effectively people homelessness drug dependencies poor social networks,mental issues other social determinants of health that place these at risk outcomes. Special Support Coordinators fill huge gap pulling together siloed parts multiple service systems overlap disability supports stakeholder noted lack clear expectations and scope for support made it hard ensure appropriate hours Plans common 10 hours over two-three years but almost entirely utilised the `

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# DISCLOSURE LOG

initial meetings undertaking administrative tasks.
This left few hours remaining for Support Coordinators
to provide tangible supports past initial meetingsthis.left.few.or.no.hours.remaining.for.Support.Coordinators.to.provide.tangible.supports.past.the.initial.meetings.Another Member noted that a person who has received across two years that it is incredibly difficult to set and meet Participant's expectations.This member stated it inappropriate for agency put support coordinators in position claiming someone outside their allocated without being able do anything more aid them as could run risk participant choosing less qualified or appropriate coordinator.Some submissions noted Level funding does participants with sufficient hours effectively supported particularly Scheme when supporting through crisis situation.The Australian Community Industry Alliance.stated:[There remains sense ACIA feedback there inconsistent allocation coordination clear guidelines assignment such requirements.Working Group members submisions need flexibility delivery support including:Needing absorb hidden administration costs plan changes participant dies circumstances change working group expressed concern often required solve problem gave examples times they received correspondence from NDIA recommending undertake activities will not be reimbursed.A member of Working Group.expressed issue follows:A Change Circumstances submitted request additional support coordination funding NDIA however major delays response service providers forced pro bono which impacts financial viability case of crisis situations -Support Coordinators manage these by providing intensive stabilise impact crisis participant are often forced use minimal hours.Merri Health said majority clients have very complex needs most often inadequate built into plans access supports staff having review extensions unfunded time.Support greater trust closer relationship between participants Support Coordinators arguing that support coordination based on transactional manner can lead detrimental outcomes.Wellways stated experience psychosocial participants confusion around services Coordinator provide limited role sometimes difficult
---

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# Disclosure Log
## Pricing Arrangements
The DIA submission contained a detailed proposal for support coordination pricing.
Other submissions noted that prices limits for support coordination were not increased in-line with other disability support price limits implemented on July 07/25-2421 despite increasing cost pressures labour hiring costs technology etc Submissions proposed price limits for support coordination be indexed line Consumer Price Index CPI changes superannuation SCHADS fair work increases Submissions outlined challenges attracting and retaining staff as result inability compete salary packages sectors Rocky Bay noted current price limit does allow providers competitive attract recruit staff able effectively undertake role The submission from Council Regional Disability Services stated providers often need pay higher salaries to attract necessary highly qualified members which leads overheads due service demand average base salary The submission provided case study challenging appropriately qualified staff within current structure: ...the pricing regime supports coordination recognises complexity needs high level qualifications Many organisations are paying much higher levels SHADS Level -6 acknowledging participants still looking Support Coordinators being case managers taking lot direct accountabilities wellbeing rather than just coordinating services These roles require more supervision training but is recognised however these higher costs deliver this reflected NDIS prices Members stated Level III Support Coordinators should paid same award specialist behaviour intervention or therapeutic supports employed under Health

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# DISCLOSURE LOG

awards *not* the SCHADS Award.
This proposal was built upon the notion that Level 3 Support Coordinators were generally groups comprising clinicians possessing higher skillsets and qualifications.*
one member noted it important acknowledge participants requiring level support coordination also expected their Support Coordinator be able manage crises mitigate recurrence such in future members proposed Specialist Support Coordinators registered with Australian Health Practitioner Regulation Agency Association Social Workers*
oned raised comparability between role Recovery Coach a Support Coordinator they further clarification needed funding psychosocial recovery coach versus support coordination price limit for Recovery Coaches increase line support recognition emerging specialisation Submissions state current price limits on support are insufficient to cover costs operations Further detailed submission from DIA other submissions raise issues fall following three broad areas:
- Non-billable hours;
Allowance travel;and Workforce attraction retention**Non-billable hours***Consultations overall revealed participants did not get sufficient hours plans support Coordination Providers indicated often provided continuity supports meet duty care standards participant allocated funding utilised but this comes cost financial viability Autism Queensland stated largest non billable costs attending planning meetings client NDIA PartnersNDIS staff conducting planning meetings actively ask participants needs may have themselves so Plan appropriately reflective of participant's needs reducing likelihood review lodged costly stressful time-wasting exercise They stated whilst good practice valued by participants families carers additional cost absorbed business without payment Living My Way reported small team 295 hours non-billable supports including providing services despite inadequate funding needing provide two Support Coordinators complex needs or risk environment,team case reviews training supervision Senior Support
1 See: Disability Intermediaries Australia (S061), genU Interaction Services Spinal Cord Injuries Australia S047) and We Are Vivid (S035). And see Australian Community Industry Alliance (S025), Autism Queensland (S144), Community Assist One Door Mental Health (S097), Paragon Limited (S208).
Community Assist Submission p. **OFFICIAL Page of

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# DISCLOSURE LOG
The **National Aboriginal Community Controlled Health Organisation** stated that in remote and very remote Aboriginal and Torres Strait Islander communities, price arrangements need to include sufficient funding allocation for travel and subsistence funding (ε.g., Medical Outreach Indigenous Chronic Disease Program type funding). They said: 'there are a lot of lessons that can be learnt from the health sector on the provision of specialist and allied health services to remote communities which directly transferable NDIS.'
Submissions also noted current travel policy as administratively burdensome because provider travel funds accessed through participant's individual plan; these administrative steps must completed prior service provision every participant.
The Australian Orthotic Prosthetic Association submission states orthotist/prosthetists require:
- Ensure each participant has their plan (if not have provider travel then participant must instigate review taking long time disturbing bookings);
Obtain consent participants invoice;
negotiate hourly rates with each participant,
negotiate how will apportion between participants when multiple attendants example monthly clinic attended ten).
Australian Orthotic Prosthetic Association submitted current NDIA provider travel means it is difficult providers establish efficient sustainable provider travel absorbing costs unsustainable resulting some reducing number outreach clinics refusing operate any relying state-based support operating clinics. Other Vision Australia separation centre capital causing complexity extensive burden implementing significant investment client management billing systems gains minimal. In its submission, the Ngaanyatjarra Pitjantjatjara Yankunytjatjara Women’s Council suggested lack clarity in guidance leads organisation understand many recoup.

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## Source release page 686

# DISCLOSURE LOG
## OFFICIAL Location Specific Issues
When working remotely, vehicles for both provider and participant transport must be 4-wheel drive,
and have these high lease, maintenance, and fuel consumption costs, as well as requiring specific
driver training.
Maintenance costs for one 4-whell drive vehicle amount to around $90 per year,
extensive least cost ($ additional pa).
The cost in remote locations up a dollar higher than more populous areas Australia For safety workers participants when traveling roads where there phone reception each needs satellite phone an epib which entail ongoing costs usage Many overheads that occur regardless staff are able travel out Lands visit clients.
Members South Australia noted added costs providers incurred manage COVID-19 said were not adequately reflected model One member stated has meant reliance Agency staff paying overtime factored into current pricing arrangements They their organisation paid $3k overtime PPE Another Member noted their had spent $54k last three months on including RATS compensation from agency Members of SA group WorkCover levies expensive other states argued rates % & .% not appropriately reflected DSW Cost Model set at %.%
They should addressed either bringing state's arrangement alignment with jurisdictions (a government matter) or by NDIA allowing price limits South Australian members Queensland discussed DSW Cost Model account increased work cover costs result increase number calling sick claiming based adverse vaccine affects something cannot avoided because vaccinations mandatory
South working group also Quality Safeguard Standards is more expensive other states due South Australian government Authorising Coordinators unlike others did Submissions Western Australia argue the compliance reporting higher other states The and groups Queensland South public holidays reflected Pricing Arrangements example given SIL services only funded 2016 public holiday in Queensland half day Christmas Eve New Years' Eve South while providers can use support items for supports delivered each public holiday there was insufficient funds plan allow this happen This means provider needed absorb cost which adds overheads

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# Disclosure Log
## Other Issues - Remote and very remote
The Council of Regional Disability Services submission stated that the costing model does **not** recognize costs when providers become de facto last resort in remote communities.
They said some are filling gaps left behind State Governments who exited during transition NDIS services delivery period; they also noted need responsibility continue providing supports these areas despite lack financial benefit doing so.
Life Without Barriers submitted new model needed address complexities delivering disability support remotely achieve better outcomes;
it argued tinkering current pricing structure won't deliver people with disabilities living there,
citing NDIA's co-design approach fully supported Alliance20.
### Aboriginal Torres Strait Islander
NACCHO (National Aboriginal Community Controlled Health Organisation) submission highlighted significant unmet needs for Indigenous participants, citing absence culturally appropriate supports as reason this demand remains unsatisfied.
The Ngaanyatjarra Pitjantjatjara Yankunytji Women’s Council similarly emphasized NDIS takes little account peoples' lifestyles backgrounds plans written English incomprehensible language Anangu culture oral based traditional languages goals reflect access basic needs often focus on unavailable services to clients excessive paperwork sign.
[NACCHO] Despite clear challenges facing Australia's Indigenous population ACCHOs sector can redress inequalities but 2021 Annual Price Review consultation paper never mentions or acknowledges us evidence suggests only will use ACCO available.

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## Source release page 688

# DISCLOSURE LOG
## OFFICIAL Location Specific Issues
The NACCHO submission also called for reform to the funding of supports in remote and very remote Aboriginal and Torres Strait Islander Communities.
It stated that:
> [In] In **2019**, the COAG Disability Reform Council agreed to use a more flexible approach to address market challenges in the NDIS and recognised 'a `one size fits all`'approach to deliver NDIS *is*not suitable to address market gaps faced by geographic location*, particular cohorts,*and certain disability types'ootnote{Ibid., p.* \textbf{*}**\_8*.}

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# DISCLOSURE LOG

workforce from Perth. Despite there being demand services Geraldton organisation unable make work P&L perspective because prices are reflective realities working Geraldton Another Member agreed that "Geraldton Carnarvon most challenging areas deliver services" deserved recategorisation.
The submission Avivo argued Southern Cross Dongara should also be classified Isolated Towns.`Dongara minutes drive away Geraldton population approximately `30 It very challenging recruit support workers town and they unavailable planned either needs cancelled incur costs sending a support worker Geraldton cover essential`Southern Cross Remote km east Very Remote has population less than Merredin which is about km away This closest in which Avivo small team employees it undertake task building workforce Southern Cross meet few customers require service`▫Avivo Submission S p .

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## Source release page 690

# Disclosure Log
## OFFICIAL
### Appendix A – List of Submissions

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## Source release page 691

# Disclosure Log
| Reference | Type of Respondent | Respondent |
|-|:-:|--|
S050 & Individual Support Worker/Therapist & Active Ability \
s051 & Individual Support Worker/Therapist & The Active Studio \s052 & Individual Support Worker/Therapist & Lane Cove Physio \s053 & Provider Peak Body & Specialist Disability Accommodation Alliance \s054 & Provider & At Home Care \s055 & Provider & Action on Disability within Ethnic Communities \s056 & Provider & Lizard Centre \s057 & Individual Support Worker/Therapist & NeuroRehab Allied Health Network \s058 & Individual Support Worker/Therapist & NeuroRehab Allied Health Network \s059 & Individual Support Worker/Therapist & NeuroRehab Allied Health Network \s060 & Provider & We are Vivid \s061 & Provider & NDIS Services \s062 & Individual Support Worker/Therapist & Thomas Nicholas (sole trader) \s063 & Individual Support Worker/Therapist & NeuroRehab Allied Health Network \s064 & Professional Peak Body & The Australian Orthotic Prosthetic Association \s065 & Provider & Empowered Futures \s066 & Provider & Autism Spectrum Australia (Aspect) \s067 & Provider & Community Support Inc. \s068 & Provider & NeuroRehab Allied Health Network \s069 & Provider & MED-EL \s070 & Professional Peak Body & Exercise “ Sports Science Australia ESSA )\s071 & Participant Representative & NDIS Participant's Father \S 072 & Provider Peak Body & Council of Regional Disability Services CORDS S073 & Individual Support Worker Therapist RE Physiology \S O74 & Individua lSupportWorker Thera pist The EP Clinic \SO75 & Individual Suport Workr Therap ist Active Ability \so76 & Individual Support Worker/Therapist Flex Out

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# DISCLOSURE LOG
## OFFICIAL Appendix A - List of Submissions
| Reference | Type of Respondent | Respondent |
|-:|:-:|:-|
| S03 | Provider | Community Assist |
| S104 | Provider | Illawarra Disability Alliance |
| S105 | Provider | Mind Australia |
| S106 | Provider | Mercy Connect |
| S107 | Provider | Hireup |
| S108 | Provider | Marathon Health |
| S109 | Provider | Vision Australia |
| S110 | Participant Representative Organisation | Queensland Advocacy Incorporated |
| S111 | Professional Peak Body | Allied Health Professions Australia |
| S111a | Professional Peak Body | Allied Health Professions Australia |
| S112 | Provider | Avivo |
| S113 | Individual Support Worker/Therapist | Active Ability |
| S114 | Individual Support Worker/Therapist | Move 2 Thrive |
| S115 | Individual Support Worker/Therapist | Optimum Health Services |
| S116 | Individual Support Worker/Therapist | Optimum Health Solutions |
| S117 | Individual Support Worker/Therapist | Better Exercise Physiology |
| S118 | Individual Support Worker/Therapist | Optimum Health Solutions |
| S119 | Individual Support Worker/Therapist | Uplift Exercise Physiology |
| S120 | Provider | Living My Way |
| S121 | Provider | Flourish Australia |
| S122 | Union | Australian Services Union |
| S123 | Union | United Workers Union |
| S124 | Provider | Oncall Accommodation Services |
| S125 | Provider | IOTAH |
| S126 | Provider | Activ |
| S127 | Provider | Connect Plan Management |
| S128 | Provider | Down Syndrome Australia |
| S129 | Provider | Jobs Are Us |
| S130 | Participant Representative Organisation | Gippsland Disability Advocacy |
| S131 | Provider | NeuroRehab Allied Health Network |
| S132 | Individual Support Worker/Therapist | Life in Action |
| S133 | Individual Support Worker/Therapist | Hunter Rehabilitation and Health |
| S134 | Individual Support Worker/Therapist | Effect Exercise Physiology |
| S135 | Individual Support Worker/Therapist | Active Ability |
| S136 | Individual Support Worker/Therapist | o² active |
| S137 | Individual Support Worker/Therapist | KG Exercise Physiology |
| S138 | Individual Support Worker/Therapist | Active Ability |
| S139 | Provider | North East Exercise Solutions |
| S140 | Individual Support Worker/Therapist | UniquePhysio |
| S141 | Provider | Rocky Bay |
| S142 | Provider | Supporting Independent Living Co-Operative (SILC) |
| S143 | Provider | Minimbah |
| S144 | Provider | Autism Queensland |
| S145 | Provider | Bedford |
| S146 | Individual Support Worker/Therapist | Darling Downs Therapy Services |
| S147 | Provider | Carers ACT |
| S148 | Provider | RDNS SA |
| S149 | Participant Representative | NDIS Participant Carer |
| S150 | Provider | National Aboriginal Community Controlled Health Organisation (NACCHO) |
| S151 | Provider | Galway Trading |
| S152 | Provider Peak Body | National Disability Services (NDS) |
| S153 | Provider | Mental Illness Fellowship of Australia |
| S154 | Provider | Novita |

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## Source release page 693

# Agency.

## Insurance
### Disability
#### National
##### Released information:
The act that was

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## Source release page 694

# DISCLOSURE LOG
## OFFICIAL Appendix A - List of Submissions

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# Disclosure Log
OFFICIAL
## Appendix B – Working Group Members
### Working Group 1 - Core Pricing Arrangements
| Organisation represented | Attendee at least session |
|-|-
| Ability First | Andrew Rowley|
| Ability First | Michael Bink|
| Achieve Australia | Lorraine Salloum|
| Autism Spectrum Australia Aspect | Nikki Lui|
| Avivo | Lynsey McDonnell|
| Bedford | Rachael Griffiths|
| Cerebral Palsy Alliance | Shaun Curry|
| Cerebral Palsy Alliance | Tim Pines|
| Challenge Community Services | Dino Santos|
| Civic Disability Services Ltd | Ethan Chishty|
| Civic Disability Services Ltd | Kimberley Rathmanner|
| Community Living Options | Lauren Cronin|
| Community Living Options | Tiff Hodge|
| CPL Choice Passion Life | Murray Sandon|
| Fighting Chance | Laura O'Reilly|
| Golden City Support Services | Shelley Moore|
| Greenacres | Chris Christodoulou|
| HireUp | Liam Caulfield|
| Life Without Barriers | Steve Sloan|
| Macarthur Disability Services | Brenda Odewahn|
| Mambourin | Alma Zulovic|
| Mind Australia | Anath Dissanayake|
| Minda | Antony Sellentin|
| Minda | Nathan Thompson|
| National Disability Services | Kerrie Langford|
| Northcott | Pat Buick |
| Oak Possibility | John Rowland|
| Oak Possibility | Jon Anning|
| Rocky Bay | Adam Maxwell|
| Stride | Emma Thomas|
| Sylvannvale | Oliver Parker|
| The Disability Trust | Suze Mandicos|
| The Housing Connection | Nicola Hayhoe|
| Unisson | Rayni Gauci|

### Working Group 2 - Quality and Safeguard Costs
| Organisation represented | Attendee at least session |
|-|-
| Ability First | Andrew Rowley|
| Ability First | Jennifer Luff|
| Ability First | Michael Bink|
| Achieve Australia | Ranita Chatterjee|
| Achieve Australia | Tina McManus|
| ACT Government | Michelle Waterford|
| Allied Health Professions Australia | Erin West|
| Australian Physiotherapy Association | Carole Sarasa|
| Australian Physiotherapy Association | Carolyn O'Mahoney|

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# DISCLOSURE LOG
## OFFICIAL Appendix B - Working Group Members
| Organisation represented | Attendee to at least one session |
|-|-
| Australian Physiotherapy Association | Dan Miles|
| Autism Association of Western Australia | Nicola Abernethy|
| Avivo | Dannielle Wenn|
| Avivo | Denver Forsdike|
| Avivo | Janine Croker|
| Avivo | Lisa Davies|
| Bedford | Taryn Alderdice|
| Better Rehabilitation | David Pettersson|
| Cara | Todd Williams|
| Carpentaria Disability Services | Annie Riley|
| Cerebral Palsy Alliance | Elise Taylor|
| Choice Passion Life | Amelia Rowell|
| Choice Passion Life | Robert Irvin|
| Civic Disability Services Ltd | Carrie Voysey|
| Endeavour Foundation | Eric Teed|
| Endeavour Foundation | Jaime Zischke|
| Endeavour Foundation | Jennifer Knight|
| HireUp | Liam Caulfield|
| Life Without Barriers | Greg Reynolds|
| Macarthur Disability Services | Brenda Odewahn|
| Minda | Amy Ambagtsheer|
| NDIS Commission | Samantha Taylor|
| National Disability Services | Carmen Pratts-Hincks|
| National Disability Services | Kerrie Langford|
| National Disability Services | Philippa Angley|
| Northcott | Aleta Carpenter|
| Novita | Andrea Collett|
| Novita | Tara Richards|
| Nulsen Group | Gordon Trevern|
| Oak Possibility | John Rowland|
| Oak Possibility | Jon Anning|
| Occupational Therapy Australia | Madison Silver|
| Occupational Therapy Australia | Michael Barrett|
| Occupational Therapy Australia | Samantha Hunter|
| Scope (Aust) Ltd | Ian Morgan|
| Scope (Aust) Ltd | Richard Drew|
| Stride | Emma Thomas|
| Sylvanvale | Leanne Fretten|
| Sylvanvale | Tammy Sargeant|
| Therapy Focus | Danelle Milward|
| VIC Department of Families, Fairness and Housing | Christopher Brophy|
| VIC Department of Families, Fairness and Housing | Heidi Tarjani|
| VIC Department of Families, Fairness and Housing | Shaun Nicholson|
| WA Department of Communities | Susan Quinn|

## Working Group 3 - Group Pricing Arrangements for Core Supports
| Organisation represented | Attendee to at least one session |
|-|-
| Ability First | Andrew Rowley|
| Ability First | Michael Bink|
| Allevia | Philip Petrie|
| Autism Spectrum Australia (Aspect)| Ben James|
| Bedford | Stefanie Veitch|
| Centacare | Kaylene Moore|

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# DISCLOSURE LOG
| Organisation represented | Attendee to at least one session |
|- |-|
| Central Bayside CHS | Amrita Ahluwalia |
| Cerebral Palsy Alliance | Anne-Marie Bell |
| Cerebral Palsy Alliance | Paul Henderson |
| Cerebral Palsy Alliance | Shaun Curry |
| Disability Services Australia | Heath Dickens |
| Flourish Australia | James Herbertson |
| Greenacres | Chris Christodoulou |
| HireUp | Peter Willis |
| Life Without Barriers | Steve Sloan |
| National Disability Services | Graeme West |
| National Disability Services | Philippa Angley |
| Nexus Inc.| Mark Jessop |
| Northcott | John Preston |
| Novita | Greg Ward |
| Novita | Jeremy Brown |
| Rocky Bay | Adam Maxwell |
| Stride | Emma Thomas |
| Sunnyfield | Belinda Gannon |
| Sunnyfield | Matt Parrott |
| The Disability Trust | Suze Mandicos |
## Working Group 4 – Temporary Transformation Payment
| Organisation represented | Attendee to at least one session |
|- |-|
| Ability First | Jennifer Luff |
| Autism Spectrum Australia (Aspect) | Nghi Hua |
| Avivo | Lynsey McDonnell |
| Bedford | Tahlia Gradara |
| CareChoice | Michelle Eriksen |
| Centacare | Derek Millar |
| Community Living Australia | Mark Kulinski |
| Dared Disability | Andrew Daly |
| Ermsha | Michael Bowers |
| Flourish Australia | Megan Hancock |
| HireUp | Liam Caulfield |
| Life Without Barriers | Nelson Contador |
| National Disability Services | Henry Newton |
| National Disability Services | Karen Stace |
| Nextt | Simon Wright |
| Northcott | John Preston |
| Rocky Bay | Adam Maxwell |
| Sunnyfield | Peter Dixon |
## Working Group 5 - Therapy supports
| Organisation represented | Attendee to at least one session |
|- |-|
| Ability First | Andrew Rowley |
| Ability First | Michael Bink |
| Allied Health Professions Australia | Dr Chris Atmore |
| AMTA | Helen Cameron |
| Autism Spectrum Australia (Aspect)| Maryanne Pease |
| Autism Spectrum Australia (Aspect)| Rachel Kerslake |
| Autism Spectrum Australia (Aspect)| Rebecca Keane |
| Audiology Australia | Feiya Zhang |

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## Source release page 698

# DISCLOSURE LOG
## OFFICIAL Appendix B - Working Group Members
| Organisation represented | Attendee to at least one session |
|- |-|

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# Disclosure Log
## Working Group 6 - Nursing supports
| Organisation represented | Attendee to at least one session |
|- |-|
| Achieve Australia | Tina McManus |
| At Home Care | Christian Lenzarini |
| Australian Primary Health Care Nurses Association (APNA) | Jayne Lehmann |
| Blue Care | Jo Martinaglia |
| Blue Care | Sue Macgregor |
| Canberra Health Services | Barbara Bolton |
| CareChoice | Michelle Eriksen |
| Civic Disability Services Ltd | Rebecca VanLierop |
| Continence Foundation of Australia | Janie Thompson |
| Eskleigh Foundation | Sharlene Knight |
| Home Care Nurses Australia | Busi Faulkner |
| Intensive Care at Home | Patrik Hutzel |
| NNA Direct Support Service | Ellen Banks |
| NNA Direct Support Service | Joanne Kernot |
| Yooralla | Kristy McMurray |

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# DISCLOSURE LOG
## OFFICIAL Appendix B - Working Group Members
| Organisation represented | Attendee to at least one session |
|-|-
| Facilitatrix | Caroline Marshall|
| genU | Brandon Howard|
| genU | Schree Barry|
| Golden City Support Services | Shelley Moore|
| Life Without Barriers | Nelson Contador|
| Life Without Barriers | Nicole Harrop|
| Macarthur Disability Services | Brenda Odewahn|
| Melbourne City Mission | Ben Spooner|
| Melbourne City Mission | Julia Henning|
| Mercy Community | Kimberley Dillon|
| Mind Australia | Elena Slodecki|
| Mind Australia | Nicola Ballenden|
| National Disability Services | Karen Stace|
| Stride | Emma Thomas|
| Stride | Juliet Middleton|
| Support Coordination Academy | Mary Ingerton|
| Wellways Australia | Laura Collister|
| Wellways Australia | Michael Ashenden|
| Wellways Australia | Nikki Wynne|
| Your Plan Manager | Tanya Walford|
### Working Group 9 – Regional and Remote
| Organisation represented | Attendee to at least one session |
|-|-
| Avivo | Christine Gibson|
| Avivo | Nichole Kostal|
| Council of Regional Disability Organisations | Kathy Hough|
| Department of Communities Tasmania | Ingrid Ganley|
| Department of Seniors and Disability Services and Aboriginal and Torres Strait Islander Partnerships | Elizabeth Rowe|
| East Kimberly Job Pathway | Laura Little|
| HireUp | Liam Caulfield|
| Hireup | Larissa Silva|
| Ingham Disability Support Services | Liz Sutton|
| Life Without Barriers | Scott Ferguson|
| Midway Community Care | Heath Flanagan|
| MJD Foundation | Nadia Lindop|
| National Disability Services | Ian Montague|
| Novita | Cathryn Blight|
| NSW Disability Secretariat | Amanda Viner|
| NSW Disability Secretariat | Brian Woods|
| Occupational Therapy Australia | Michael Barrett|
| Office of Disability | Michelle McColm|
| Speech Pathology Australia | Erin West|
| St Giles | Andrew Billing|
| Through Life Physio | Helen|
| WA Department of Communities | Suzanne Velarde|

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# Disclosure Log
## Working Group 10 - Queensland
| Organisation represented | Attendee at least session |
|- |-|
| **Organisation Represented** | **Attendee To At Least One Session** |
| `121 Care` | Kym Chomley |
| CPL-Choice Passion Life | Murray Sandon |
| Department Of Employment Small Business And Training | Tim Maloney |
| Endeavour Foundation | Eric Teed |
| Endeavour Foundation | Jennifer Knight |
| Ingham Disability Support Services | Liz Sutton |
| National Disability Services | Ian Montague |
| Xavier | Richard Littler |
| Yumba Bimbi Support Services | Rachel Freeman |

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## Source release page 702

# Disclosure Log
## FOR OFFICIAL USE ONLY
### DOCUMENT 54
**ndis Delivered by the National Disability Insurance Agency**
# Pricing Arrangement Reference Group (PARG)
Meeting: **7 February 2023**

| Members |
|-|
|| Chair || David Gifford | A/g Scheme Actuary | By Teams |
|| Pricing Reference Group Members || Deborah | Independent Member | By Teams |
Julie | PSM | Independent Member | By Teams |
Lynne | PSM | Independent Member | By Teams |
Jim | PSM | Independent Member | By Teams |
|| Participating Observer nominated by CEO || Gerrie | General Manager, Provider and Market Development | By Teams |
Kee | A/g Branch Manager, Economics and Pricing | By Teams |
Jenny | Director, Economics and Pricing Branch | By Teams |
|| Secretariat || Davor | A/g Director, Economics and Pricing Branch | By Teams |
Vincent | A/g Director, Economics and Pricing Branch | By Teams |

1. Declaration of Conflicts of Interest
The Chair ASKED members if they had any updates of conflicts of interest to declare.
PARG members did not have any updates.
## Apologies
- Dr Lynn
### Update by the Chair
The Chair INFORMED the PARG:
* The recent membership appointment of Graeme AM to the NDIA Board alongside Graeme's appoint was welcomed Kurt AO as new Chairman Ms Maryanne AO Denis AO and of Dr Rebecca Falkingham recently appointed Chief Executive Officer NDIS Review will look at design operations sustainability It also looks ways make market workforce more responsive supportive sustainable PARG discuss NDIAs approach Annual Pricing Review (APR) for 2022–23.

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# Disclosure Log
## Pricing Arrangement Reference Group Meeting - Minutes
### Annual Pricing Review (APR) 2022-23
The Chair walked members through key points of the paper:
* **Outcome:** Board's decision from the 2021–22 APR introduced a *temporary price loading*. This percentage is combination: 
   + `+` relating to changes in the SCHADS award.
   + `+` applied temporarily at NDIA level (`NDIA`).
* **Therapy support limits not updated since July** last changed; providers anticipate CPI passed onto therapy prices as per NDIS review.
* **Cost Scheme increased significantly**, projected $90 billion GDP share expected by year-end and could reach up-to-date levels.
* **Concurrent with NDIS review,** there are areas overlapping between both processes ensuring no foreshadowing outcomes for NDIS review.
* **Minimum wage overlaps heavily, closing gap.** Aged Care market overlap disability market.
* **SDA pricing review effective on January next year,** separate process compared to main annual review.
The General Manager raised comments related specifically regarding:
* **Market expectations management**: Market conditions affecting support price limits need communication plan to maintain confidence;
* **Uplift mergers acquisitions across sector.** Media reports Anglicare Tassie Encompass Geelong examples provided,
* **New approach financial benchmarking survey (FBS) eligibility criteria:** Agency adopting new method closely working sectors gauge data required update Disability Support Worker Cost Model.
PARG members discussed Annual Price Review 2022-23 paper including concerns such that:
* **Decision FBS run allowed sector take carriage of process in the market. Concerns about risks unable efficient cost model absent FBS updates needed addressed through a communication plan maintaining market confidence;**
* **Efficient costs achieved via NDIA price limit understanding from one member noted.**
* **Optimal level efficiency movements time questions asked. Also inflationary changes prices might impact those efficient prices. Managing market expectation challenging with recent SCHADS award changes split shifts into DSW Cost Model considered clarification option passing Fair Work Commission’s minimum wage increase minus `+` temporary loading for COVID, permanent addition would require strong arguments productivity.

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# Disclosure Log
## Pricing Arrangement Reference Group Meeting - Minutes

factor, which is broken down into two components would support argument for the removal
due:
- catch up efficiency (Direct cost of equipment), labour productivity discounting real increases) People not being able as willing e.g., member household unwell words,
today tend be overly cautious when making decision work.

### Final Comments
The Chair thanked everyone who attended meeting and acknowledged its short duration due scheduling constraints welcomed further comments or feedback from members via Secretariat.

#### Next Meeting
Expected following March confirmation close.

Pricing Reference Group Meeting Agenda

Disclosure Log

National Disability Insurance Agency

Pricing Reference Group Meeting Agenda

Pricing Reference Group Members

Participating Observer nominated by CEO Lisa DCEO Markets Government and Engage Group |By Teams|

Participating Observer nominated by Department of Social Services Luke GM Strategic Policy Markets Safeguards |By Teams|

Disclosure Log

Pricing Reference Group (PRG)

Meeting: 29 March 2022

Minutes

Members

Pricing Reference Group Members:

Secretariat Vincent S47Fpersonalpr AGDirectorPric ingOperations By Teams Jodie Snr Engagem ent OfficerProv iderEn gage mentBran ch By Teams ScottS47FPerson al Priv a DirectorAnnualPriceReviewTeam By Teams Dominic S 47 FpersonAGAssistantD irectorAn nualPri ceRe viewTe am By Teams

ConfirmationOfThePreviousMeeting’sMinutes:

Disclosure Log

Update by the Chair

Core Supports – Disability Support Worker (DSW) Cost Model

High Intensity Supports*

Therapy Supports*

Disclosure Log

Disclosure Log

National Disability Insurance Scheme Annual Pricing Review 2021–22 DRAFT Report on Consultations April 2022

DISCLOSURE LOG

OFFICIAL

Copyright

Use Of National Disability Insurance Agency Material

Disclosure Log

OFFICIAL

Table of Contents

Introduction…5

Terms of Reference of the Review …5

Consultation Paper ….7

Working Groups….7

Core Pricing Arrangements …..9

Group Based Core Supports……35

Temporary Transformation Payment ……48

Quality Safeguarding Costs ……..57

Therapy Supports .72

Pricing Arrangements…72

Disclosure Log

OFFICIAL

Introduction

Terms Reference review were established Board They required Agency examine engagement participants community government stakeholder targeted research whether Scheme existing price control framework (pricing arrangements limits) continues appropriate or should modified In particular agency required:

DISCLOSURE LOG

Disclosure Log

Official Introduction

Consultation Paper

Working Groups Twelve stakeholder working groups established:

DISCLOSURE LOG

Core Pricing Arrangements

Pricing Strategy

DISCLOSURE LOG

DISCLOSURE LOG

OFFICIAL Group Based Core Supports

DISCLOSURE LOG

DISCLOSURE LOG

OFFICIAL Group Based Core Supports

Disclosure Log

OFFICIAL

Temporary Transformation Payment

DISCLOSURE LOG

OFFICIAL Temporary Transformation Payment

DISCLOSURE LOG

DISCLOSURE LOG

OFFICIAL Temporary Transformation Payment

DISCLOSURE LOG

DISCLOSURE LOG

OFFICIAL Temporary Transformation Payment

Future of the TTP

DISCLOSURE LOG

DISCLOSURE LOG

OFFICIAL Temporary Transformation Payment

MR25/01967 FOI 24/25-2242 into the NDIS.

DISCLOSURE LOG

Quality and Safeguarding Costs

Disclosure Log OFFICIAL

Section: 5 - Quality and Safeguarding Costs

A total of submissions about costs ensuring quality/safety supports people disability received in response Consultation Paper Details Appendices provided Working Group providers stakeholders established had members organisations met video-conference times February March.

DISCLOSURE LOG