NDIA Board meeting of 25 May 2023

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DISCLOSURE LOG

DOCUMENT 62

OFFICIAL: SENSITIVE

NDIS Board meeting of May 25th, The contentsof this document are OFFICIAL:SENSITIVE Agenda Item: # Agenda Item: Annual Pricing Review €₽-₼ Paper Type: For Decision SLT Sponsor: David Gifford, Scheme Actuary

Purpose

To seek approval for APR draft recommendations & release Draft Report (Attachment A).

Recommendation

That The Board approves these Recommendations, including the Draft Report.

Research And Analysis

An overview was presented on April (\underline{28}), 2023; research completed now. The Consultation Paper’s feedback summary provided at last board meeting in April ‘23 after incorporating late submissions resulted with a total submission count (through consultation process) being (=_{total}^{304} ext{s}.) Business dynamism analyzed examining DSWs’ level activity across therapy support coordination and plan management areas. Ability Roundtable conducted benchmarking survey involving 24 providers mainly large market dominating players. Topics included SCHADS Award changes, COVID-19 impacts, compliance costs.* These results were incorporated into report.Private billing rates compared NDIS prices to private sector using regression analyses* estimated hourly cost of supply.*

Key Draft Recommendations

Below are key draft recos., full list see Executive Summary(AttachmentA) .

Recommendation: Increase price limits determined by NDIS Cost Model each July reflecting minimum wages specified in Social Community Home Care Industry Awards following Fair Work Commission’s Annual Wage Review & any increase Superannuation Guarantee Charge.“”“ — OFFICIAL: SENSITIVE — Annual Pricing Review €₽-₼ USE FOR BOARD Pg 748/Total pages = 1,049

DISCLOSURE LOG

OFFICIAL: SENSITIVE ndis logo here*

NDIA Board meeting of 25 May 2023

Recommendation 2

The NDIA should reduce the temporary loading applied to the NDIS Disability Support Worker Cost Model to 1% from July 2023, with the temporary loading ceasing in June or December depending if it’s a leap year.

Recommendation 3

The NDIA is advised that consideration be given towards including paid family leave into the Disability Support Worker Cost Model as part of new entitlements within industry standards; consequently an increase will occur regarding average pricing limit per hour standard weekday daytime disability support starting at .1%.

Temporary Transformation Payment Loading

Recommendation 5

Maintain current pricing strategy for TTP and allow providers who have been claiming TTP during financial years can continue until cessation while those not claiming are prohibited under this fiscal period.

Therapy Supports

Recommendation 6

NDIS does not make any structural adjustment, nor index price limits on therapy supports effective July next year (i.e., no change).

Support Coordination

Recommendation 8

No changes made by NDIA relating to coordination services. Indexation applies only Level-1: Connection Services but not Levels -2 & -3, which remain unchanged.

Plan Management Supports

Recommendation 11

Not making adjustments related plan management fees, also no indexing occurs here either.

Other Supports

OFFICIAL: SENSITIVE Annual Pricing Review (APR) 2022- can’t determine what exactly was meant with ‘can’ or if it’s a typo to board**USE FOR BOARD* page 749 outof total pages 1049.

DISCLOSURE LOG

OFFICIAL: SENSITIVE MR25/01967 FOI 24/25-2242

NDIA Board meeting of 25 May 2023

Recommendation 12

The NDIA, subject to any specific recommendation arising from the current Annual Pricing Review and any future reviews, should: • Increase the price limits for other supports not covered by Disability Support Worker-related supports on 1 July each year in line with the weighted movement over the previous twelve months in the ABS Wage Price Index Australia total hourly rates excluding bonuses pay and Consumer Price Index All Groups weight average eight capital cities over month preceding indexation date weighting.

Risks

Risk 5.1.Price limit therapy has increased since while support coordination Level as well plan management have been increased since There is a risk that sector will react strongly there may expectations increase some service providers withdraw market.
Risk 5.2.The temporary loading introduced was intended be measure assist providers adjust costs associated ongoing COVID SCHADS Award changes APR recommends decrease percentage from July stakeholders anticipate more assistance.
Risk TTP initially introduced at allow time continue mature reduction still pushback expected stakeholder phase out rate.

Sustainability Impacts

Assuming all recommendations put forward are endorsed SIA would impose additional expenditure $ million relative most recent Financial Sustainability Report projections November Superannuation Guarantee increase assumed interim AFSR update The comprises: • Additional expenditure $48 million for Attendant Care allowance Domestic Violence leave of included last review years unwind temporary loading percent effective implies an increase compared to AFRSAR. OFFICIAL: SENSITIVE Annual Pricing Review (APR) USE FOR BOARD Page 750of 1049

DISCLOSURE LOG

OFFICIAL: SENSITIVE MR25/01967 FOI 24/25-2242

NDIA Board Meeting on May 25, 2023

  • Increase expenditure $1 million from April-June and an additional $6 million over forward estimates through March ’28-’29 using indexing at WPI / CPI ratio. The inflation rate is as follows:
    • Consumer Price Index (CPI) - Mar’23 = +7%
    • Wage Price Index (WPI) - Mar’23 = +3%.
  • Savings in therapy ($212M), plan management ($24M); support coordination ($44M). Total savings across all categories are estimated to be $1B, with a breakdown for each category similar above but scaled up significantly due to higher numbers involved (e.g., total saving per therapy being around twice that mentioned initially). The AFSR assumes these levels of care will increase annually based upon indexation assumptions applied uniformly throughout.

Financial Impact Analysis

The actual financial impact derived by the APR largely depends heavily off decisions regarding minimum wage. As part sensitivity analysis we have also calculated sustainability impacts under both assumed increases or decreases within this range (+/-) of NMWs. Under either scenario, there’s significant variation between costs associated directly linked towards specific recommendations made during such analyses; e.g.:

  • At 5%, cost implications amounting approximately to roughly $0.3 billion and $6 million over forward estimates through March ’28-’29 respectively, or alternatively at an increased 7%; costs would rise substantially closer toward $0.9billion, which is more than double what was originally projected. The TTP allowance has been recommended as previously planned down from +1% on July’23 to zero (0) effective next year. This assumption aligns fully in line with current projections outlined earlier herein; hence no additional financial burden arises hereon.

Capital Support Indexation Approach

Capital support indexing methods are currently undergoing separate estimation processes.

NDIS Budget Initiatives Announced May 9th

NDIS budget initiatives announced last month anticipated savings totaling $4B, based upon estimated effects stemming specifically due to price freezes applied across therapy services, plan management & coordination for a period spanning two years (i.e., April-June). At base estimate levels noted above, draft proposals submitted under the framework laid out within this document anticipate delivering nearly half of these total expected benefits ($0.9bn) by way of reduced costs incurred via said measures. Future APR submissions will provide opportunities review assumptions made annually thereafter while also achieving further cost reductions relative towards November’s interim AFSR update where applicable.

Next Steps

Once approved by Board: a communication strategy will be developed and deployed alongside final recommendations slated June ’23, published formally into the Annual Pricing Report dated same month; implementation date set at July first. The indexation process itself is scheduled early during that very same month as well so as ensure all relevant balances pertaining thereto increase appropriately accordingly.

DISCLOSURE LOG

OFFICIAL: SENSITIVE MR25/01967 FOI 24/25-2242

NDIA Board meeting of 25 May 2023

Prepared by Kee Hiaujoo
Division Actuary, Data and Analysis
Phone redacted
Cleared by ELT  [ELT date]   
Approved by David Gifford Scheme Actuary

Disclosure Log

Document: NDIS - National Disability Insurance Scheme

Title:

National Disability Insurance Scheme

Annual Pricing Review *
Report*

June 2023 Delivered by the National Disability Insurance Agency. Page _[page number] outof [total pages]

DISCLOSURE LOG

Acknowledgement

The NDIA acknowledges and pays respect to the past, present and future Traditional Custodians and Elders of this nation and the continuation of cultural, spiritual and educational practices of Aboriginal and Torres Strait Islander peoples.

Copyright of the material in this document (with exceptions for third-party content) is owned and protected by the National Disability Insurance Agency (‘NDIA’). The material within excepting logos, trademarks, etc., are licensed with a Creative Commons Attribution Non-Commercial No Derivatives license version 4 International under which you may share, copy or redistribute it freely but must acknowledge ownership as ‘National Disability Insurance Agency’ along with year copyright notice ‘© National Disability Insurance Agency [year]’ while not using any part commercially without permission from agency. Reproduction subject also to CC BY NC ND conditions available on creative commons Australia site and full legal code for such materials. It’s expected that all information used will be solely beneficial towards people living disability.

Terms We Use

Acronym Meaning
ABS Australian Bureau Of Statistics
APR Annual Pricing Review
CPI Consumer Price Index DSW

Disclosure Log

Table of Contents

  • Executive Summary – page: “4”
  • Introduction – page: “14”
  • Domestic Economic Conditions and the Care Economy – page: “20”
  • Disability Support Worker Related Supports – page: “26”
  • Therapy Supports – page: “40”
  • Support Coordination – page: “55”
  • Plan Management Supports – page: “64”
  • NDIS Pricing – page: “72”

Appendixes:

Feedback from Consultation Paper (page number not provided)

Domestic & Family Violence Research (page numbers are missing, but likely around or after ‘Feedback’)

Non-Wage Aged Care Reforms (last entry on this page with a visible reference to page) - page is marked as 3 in context.

Disclosure Log

Executive summary

The National Disability Insurance Scheme (NDIS) was established in 2013 to support people with disability to pursue their goals, to help them to realise their full potential, to assist them to participate in and contribute to society. and empower them exercise choice control over lives futures.The NDIS provides funding eligible individuals (“participants”) so they can purchase open market related goods services “supports” need. The National Disability Insurance Agency NDIA monitors reviews its price control framework other market settings determine whether appropriate reflect current market conditions Annual Pricing Reviews APRs important part monitoring review process The Board developed Terms Reference guide approach requires examine engagement participants providers community government stakeholders targeted research existing price control framework pricing arrangements limits continues be appropriate or should modified As part completed extensive consultations with participants providers stakeholder Publishing Consultation Paper completing analysis submissions received Consultations other government insurance schemes Consultations Pricing Arrangements Reference Group Interdepartmental Committee Department Veterans Affairs Chief Allied Health Officer Summary Submissions Consultation Paper found Appendix A Disability Support Worker DSW supports In setting limit NDIA uses Cost Model estimate costs reasonably efficient provider deliver billable hour of support Cost Model takes account all associated every billable including base pay shift loadings salary on operational overhead supervision utilisation corporate overhead margin. These estimates set the price limits delivered by DSWs level achieved benchmarks outputs from model considers minimum employment standards provide DSW-related Australia Growth total number participant 15% providers payments continued six months December compared six months December Total submitted through Public consultation main themes raised adjustments many providers relate quality safeguards compliance COVID Social Community

Disclosure Log

2022-23 Annual Pricing Review

Home Care and Disability Services Industry Award 2010 (SCHADS Award) changes. Reponses from participants raised the concern of varying skills of support workers who were providing supports, but generally still charging at the NDIS price limit. In determining the price limit for DSW-related supports, analysis using data of the Health Care and Social Assistance (HCSA) industry was undertaken to understand the sector which disability support workers operate in. The analyses suggest that the labour market for the care sector remains tight. These conditions could potentially intensify competition in terms of labour with other care sectors, which could put more pressure on supply going forward. Despite the overall sector growth, the sector is still being impacted by COVID. The results from the 2022-23 Ability Roundtable survey shows that most surveyed providers (71%) reported that COVID was still impacting on their costs in 2022. The average percentage increase in costs due to COVID was reported at 1.5%, in line with the 1.5% cost impact estimate in the 2021–22 APR. This data is based on survey responses from 24 providers, with an average revenue of between $50 and $100 million. Similarly, the impact of the SCHADS Award changes from July 1st included changes to minimum shift time broken shifts allowances cancelled policies. The ability round table found respondents increased staffing numbers deal rostering impacts two-thirds report bottom-line costs had increases as a result average cost increase all respondents aligned estimated cost impact from the 2021–22 apr however most those increases costs been one-offs nature including purchasing new software changing rosters.The temporary loading introduced DSW Cost Model intended assist providers adjust ongoing management SCHADS Award changes Analysis suggests merits retaining reduced rate ease transition following considerations have given: • It should be recognized related restrictions economy wound back However active disrupting supports NDIS participants Providers incur some when arise such PPE RAT tests NDIS sector represents vulnerable groups community adjustments somewhat slower nation • Many needed for SCHADS Award were one-off costs providers considered still adjustment being made by sector major Awards relatively recent it takes full systems processes major Awards change NDIA recognizes there can borne providers over past year COVID reducing post pandemic many costs changes SCHADS Award off adjustments However acknowledges remains potential participant safety providers facing both transitions

Disclosure Log

MR25/01967 FOI 24/25-2242

DISCLOSURE LOG

2022–23 Annual Pricing Review

Evidence suggests that many providers have already adjusted but some are still implementing adjustments associated with COVID and SCHADS Awards changes. On balance, The National Disability Insurance Agency (NDIA) considers it necessary to extend the temporary loading for a further twelve months at one percent (1%) starting on July, which will cease in July next year (ceasing) allowing more time for transition.

  • Recommendation: The NDIA should increase price limits based upon NDIS Disability Support Worker Cost Model from July onwards reflecting any changes due to minimum wages specified within Social Community Home Care And Disability Services Industry Award 2010 following Fair Work Commission’s annual wage review or an increase Superannuation Guarantee Charge.

The NDIA also recommends extending this temporary load another twelves month at same rate, ceasing again after July.

DSW Cost Model Changes:

This model is updated annually alongside superannuation contribution increasing by .5% points up until . From this point forward all increases passed onto cost models. New paid family domestic violence leave introduced by Fair Work Commission considered; estimates suggest maximum of workers accessing such leaves would be around %. Assuming full entitlement access equates approximately as follows:. This may overestimate actual uptake sector implementation continues monitoring impact future.

Recommendation3:

Include new paid family & domestic violence into disability support worker cost model - resulting increased costs effective immediately.

Aged Care Awards Changes:

The Fair Work Commission has raised aged care worker rates relevant awards fifteen percentage points since July. While still estimated higher than comparable aged care workers, it could attract greater numbers towards the workforce given shared pool between sectors despite limited expected impacts on overall market dynamics.

Disclosure Log

Recommendation 4

The National Disability Insurance Agency should continue to work with the sector to monitor the impact of changes to the Aged Care Award that come into effect on July 1st, 2023.

Temporary Transformation Payment loading

The Temporary Transformation Payment (TTP) initially allowed providers time to assist transitioning systems more efficiently at prices lower than before. The agency has done extensive financial benchmarking over six years; thus it did not consider conducting another survey in fiscal period ending June 30th, 2023-2024 as necessary according to its initial pricing strategy framework which does see a need change timeline TTP balance between incentivizing greater efficiencies while considering differing cost structures among different providers’ access to TTPs during FY ended March 31rd., to ensure maintain those who were accessing the TTP may still require assistance transition their systems, The NDIA will closely collaborate sectors monitoring market conditions and costs structure.

Recommendation 5

  • Maintain current pricing strategy including scheduled reduction next year: Reduce temporary transformation payment from April through September 2023 to be applied until December 31 st , 2023 at rate set by NDIS Financial Benchmarking Survey conducted annually since inception of program; or cease applying this adjustment entirely after January first, following completion of said annual review process for all registered service providers claiming under TTP scheme within calendar year July third quarter continuing into fourth quarter unless otherwise notified via official communication channels such email or letterhead format issued directly by National Disability Insurance Agency (NDIA).

Therapy supports

In last half-year concluding Dec. Thirty-first day of month twelve thousand twenty-two thirty two hundred five participants purchased therapy services provided under individualized support plans funded through National Discretionary Scheme (Ndis). These health care interventions delivered across forty six thousands four hundreds three tens units representing fourteen percent increase compared with same period prior fiscal year ending June thirtieththousand nineteen twenties one; expenditure on these therapies amounted approximately sixteen billion dollars equating nearly ten per cent share outlay made towards total disbursement disbursed throughout entire duration covered by NDis ($68billion) marking significant growth over previous comparable time frame showing expansion in scope and scale. The Department Health & Aged Care reported February twentieth thirteen that number Allied Health professionals enrolled Australian Practitioners Registration Agency grew substantially up sixty-three percentage points from seven to eleven years ago reflecting positive trends expected continued job creation opportunities forecasted between seventy-fiveand ninety-ninepercent increments projected next decade based upon current demographic projections; as part comparison conducted annually comparing pricing structure against other government insurance schemes including private sector competitors, the NDIA found its rates generally aligned within range set forth by similar programs operated independently without regard for specific geographic location factors affecting overall cost structures, albeit some variations noted regarding particular types or categories service offerings available via respective platforms which may impact final determination whether any given type falls outside established guidelines governing maximum allowable charges levied pursuant to applicable legislation. The agency continues monitoring market conditions closely as they evolve.

DISCLOSURE LOG

2022-23 Annual Pricing Review

DISCLOSURE LOG

MR25/01967 FOI 24/25-2242

Disclosure Log - Annual Pricing Review between December 2020 and December 2022.

This ratio has decreased largely due to provider numbers growing overall in this period; specifically an increase from unregistered providers grew at approximately one-third rate during same time frame compared against registered service participants which saw growth around twenty-nine percent over two years. The total number submissions received for consultation process addressed support coordination services provided by NDIS price limits relating fragmented nature supports offered and unbillable hours associated their work raised concerns about these issues. A key theme both participants representatives & providers is greater clarity needed roles support coordinator plan managers aligned previous recommendations made within context of 2021–22 APR, will be considered by NDIS review. NDIA should consider any appropriate structural changes after receiving recommendation from said review. Data analysis evidence suggests new entrants market current price levels remain viable most providers deliver service given that still not mature continuing grow on balance increase recommended at present time level: Coordination Supports Level Specialist Support Coordination Services. Recommendation:

  • The NDIA should make no adjustments structurally the NDIS pricing arrangements regarding support coordinators until further notice;
    • Indexing prices for Level One (Support Connection) effective July first year ahead indexation determined Disability Worker Cost Model as per Recommendation Number One
    • Not indexing prices Levels Two Three Coordinating Specialized Service Effective July First Year Ahead. Major submission again received from DIA industry group intermediary supports plan management coordination included summary results survey conducted plans managing supporting coordinating providers costs providing service. Benchmarking survey done by DIA merit capturing specific cost drivers faced by such professionals considering ninety-two percent respondents reported having employees under SCHADS Award.

**After outcomes announced NDIS Review sector other stakeholders involved develop models required to provide services:

Level two three specialized coordinated support coordination. The NDIA also considers instances where support coordinator may undertake work following participant’s death administrative tasks associated gathering information returning equipment completing forms significant situations interactions justice health services requiring additional administrative actions including responding subpoenas or

DISCLOSURE LOG

Recommendation

The National Disability Insurance Agency (NDIA) should examine options regarding billable work that support coordinators must perform following participant’s death or other key events.

Disclosure Log

Recommendation 11

NDIADisclosure should not makeany structural adjustmenttotheNDSpricing arrangementsforplan management supports at this timeandshouldnotindextheprice limits forthemanagement fees onJuly*.

Other Supports

In absenceofspecific focuswithinAPR cycle,theNDIDiscussionsthe needtomaintainthereal valueofofNSDprice limitssupports maintaine supply ofsupporsto NDISparticipants.Furthermore,t herealsoa nee dtoallow further innovationoproviders achieve greater efficienciesimprove qualityandsafety support delivered.TheNDIDAcknowledgesthere are rangeofsupportsare under scope2022- APR and linked DSW Cost Modelwhich price limitedor benchmarked.Nursingsupportsconsider aspartthis category.Examplessupportscategoryinclude several within core capacity building such personal domestic cleaninghouse yard maintenance.Thereisneedmaintaining real values NSDPricelimits for suppostransportation to maintainsupply thesesupports NDIS participants.Thisparticularly relevant nursing with aged care reforms including wage increase those working in aged care other potential increases Nursing Award.It imperative that ensurethese remain competitive markets.May pose risk participant receiving these if there no pricingincrease deemed necessary increasethesupporthlimits previous year’s indexation methodology noted prices capital items scope review separate process.## Recommendation 12 TheNDAIAsubject specific recommendation arising current Annual Pricing Review should:

  • Increase the price limits supports thancapitalitems covered by recommendations July**weighted movement over twelve monthsABS Wage Price Index Australia total hourly rates of pay excluding bonuses ABS ConsumerPriceIndex All Groups weighted average eight capital cities) preceding March Quarter immediately preceding indexation date (with weighting).### NDIS Cancellation Policy The changed policy days align SCHADSAwardJuly **to protect staff from impact short notice cancellations feedback received participants representatives reflected too long account sudden illnesses events outside control important note maximum allowable cancellation lengthbyNDIA providers can include shorter periods.

Disclosure Log

MR25/01967 FOI 24/25-2242

Analysis: NDIA claims data from July 2020 to December 2022 shows cancellations accounted for around 0.6% DSW over this period.

This remained stable throughout with no significant change since policy update. The impact on NDIS cancellation policies based current data too early understand; sector should continue closely investigate appropriateness post APR (NDIS Review). Consider relevant Industry Awards employment standards other legislation when setting pricing policy:

  • Recommendation #13 - The NDIA work Sector Investigate Appropriateness NDIS Cancellation Policy Post Apr.

The NDIS Review

The Minister Hon Bill Shorten announced in October 2022, likely strategic implications Future NDIS Pricing Arrangements. as NDIS Review running concurrently with apr ndia committed working review team process acknowledges may impact some supports outcomes under scope ap which considered line upcoming recommendations expected Oct 2023.

  • Recommendation #14 - Continue Work With NDIS Team Relevant Topics Structural Changes Current NDIS Pricing Arrangements.

NDIS Pricing Strategy refresh

Pricing arrangements governed by the adopted Board In 2019 Since release of NDIS Pricing Strategy rapid growth provision across many types support markets delivering needed roll-out ndis Other changes include: • Growth size and Scope NDIS • Number participants supported Scheme grown increase registered unregistered providers offering services market shifting support dynamics facilitated external events economic drivers Given extent to NDIS people it supports a refresh appropriate future reviews accommodate factors better placed consider what interventions would be effective.

Disclosure Log

2022-23 Annual Pricing Review

There is a spectrum of market intervention options available to the NDIA such as market facilitation, market regulation or alternative commissioning Which intervention to use depends upon characteristics of markets how they are functioning A well-functioned market requires less invention Therefore The NDIA should examine what might be most appropriate measures apply across different markets delivering NDIS supports based present maturity economic conditions Scheme trajectory.

Recommendation (\text{number}))

The NDIA should refresh its NDIS Pricing Strategy ensuring appropriateness given current state support markets giving consideration outcomes NDIS Review.

Financial Reporting By NDIS Providers

It imperative that as Market Steward it important monitor track performance within sector ensure financially viable Previous attempts conduct surveys gauge bottom lines have resulted poor response rates therefore survey results not considered representative entire provider sector While benchmarking survey Provider Market scope APR however note beginning work with Sector introduce activity supporting better understand their position compared peers in market An effective price setting mechanism critically underpinned Agency ability track, monitor and benchmark financial performance which helps Government policy planning development This ensures representation range organisations cost bases sizes locations Moving forward model consider mandatory reporting requirements aged caresector. The NDIA explore options together NDIS Review possibility creating mandatory financial requirements Ensure sufficient information on providers’ positions assist role Market Steward inform pricing review process.

Recommendation 16:

The NDIA should explore options the potential for mandatory financial reporting from NDIS providers certain metrics.

Disclosure Log

Introduction

General

The National Disability Insurance Scheme (NDIS, Scheme) was established to support people with disability to pursue their goals, to help them realize their full potential, assist them to participate in society, contribute positively towards it; empower individuals exercising choice over lives and futures.

Administrated via Agency, The scheme has been operational for nine years since trial period concluded on July third year followed by transition phase until June twenty twentieth when became fully functional across Australia at end of said period included participants as per December thirty-first two thousand sixteen had grown significantly up till date three hundred seventy-three thousands four hundreds twelve participants. Total payments increased from ten point five billion dollars between sixteenth june nineteen eighteen through sixty-two to eight-point-six billion during same time frame ending december twelfth two-thousand-twenty-one totaling $28billion paid out within last half-year ended decembe… total payment increase annual average growth rate reached approximately seven percent annually specifically higher amounts received by SIL versus non-SIL beneficiaries respectively ($357k vs$64k). average monthly expenditure also noted significant rise among adults compared children aged zero-to-fourteen-years-old receiving services under NDIS program. in total amount spent supporting individual needs amounted 1.9 trillion Australian Dollars throughout entire fiscal year concluding Decemb…

Disclosure Log

2022–23 Annual Pricing Review

(b) Enable people with disability to exercise choice and control in the pursuit of their goals and the planning and delivery of their supports. (c) Facilitate the development of a nationally consistent approach to access to, and funding of, support services for people with disabilities, d(d) Promote high-quality innovative supports that enable individuals with disabilities maximize independent lifestyles within community inclusion.

Disclosure Log

2022-23 Annual Pricing Review

Extensive 2021–22 APR

The previous APR took place over the 2021–22 financial year and was implemented from July 1st to June **[OCR Error]th (the original text is unclear). It incorporated extensive consultations including public consultation, regular industry engagement, workshops. Recommendations included tailored pricing changes for disability supports totaling 9%, comprising wage increases under SCHADS Award plus allowance for compulsory superannuation increase (compulsory should be corrected), temporary loading at an unspecified rate ( extbf{a} $ extbackslash$%)%, base price limit adjustments (base, not extit{ extbf{*}}%), and Temporary Transformation Payment reduction in eligible supports from a specified percentage down to another specific one (%). No changes were made regarding therapy support limits or plan management costs; capital items’ prices increased according to CPI inflation rates (CPI as per document context) rather than fixed percentages.

AFSR: Financial Sustainability Report of National Disability Insurance Scheme

AFSR provides annual assessments on scheme sustainability using data up until mid-June each fiscal period. For instance: Using figures through end-of-year June, it projected total expenses would rise by $34 billion in FY-2022/23 increasing further into $89+ billion over the next decade (FY 2031–32). This represents [OCR Error] % GDP growth before reaching approximately double its current participant count (around um[group-separator={,},group-minimum-digits=5] {1_017} participants). Further increases are expected due primarily because of rising healthcare demands.

Minimum Wage Review for Aged Care Workers

On November the fourth year, FWC announced an increase ( extbf{a} $** extbackslash$%)% raise across direct care classifications within aged-care awards such as SCHADS Award and Nurses Awards covering nurses working under relevant agreements. The decision was extended from July onwards with a new agreement. The sector also undergoes non-wage reforms which must be considered when assessing worker conditions; more details can found elsewhere regarding disability support workers’ related services.

Consultations

Consultation involved advocacy groups, carers, employees, government representatives/participants, plan managers, professional bodies, providers, provider peak bodies researchers along with unions via:

  • Publication of consultation papers followed closely analyzing received submissions,
  • Other governmental insurance/funding schemes consultations,
  • Pricing Arrangements Reference Group meetings,
  • Interdepartmental Committee discussions on pricing matters.

Disclosure Log

MR25/01967 FOI 24/25-2242

Annual Pricing Review: Consultation Paper and Submissions

A consultation paper on pricing review consultations from stakeholders.

  • Consultations: With DVA & Chief Allied Health Officer. **Submissions Received: ** Released a consultation paper to assist in preparing submissions; deadline AEST Thursday April 3rd at midnight with total received including those after due date - March 8th, 2023. Most were provider organizations or employees/workers. Some came directly as participants’ representatives, professional bodies, peak providers, state governments, advocacy groups, unions etc., totaling over three hundred responses covering various topics such as disability support therapy supports, worker-related services, coordination for care, plan management costs among others.

Disclosure Log

2022-23 Annual Pricing Review

  • National Injury Insurance Scheme Queensland (NIISQ),
  • Return To Work SA (RTWSA),
  • State Insurance Regulatory Authority (SIRA),
  • Victorian Transport Accident Commission (TAC),
  • Victims of Crime Assistance Tribunal (VOCAT),
  • WorkCover QLD,
  • WorkSafe VIC, and
  • WorkCover WA.

Pricing Arrangement Reference Group

The work of the APR was overseen by the NDIA’s Pricing Arrangement Reference Group which provides advice through the Chief Executive Officer of the NDIA to the NDIA Board on price control arrangements for the NDIS This ensures coordinated activities during transition into a competitive marketplace² Current members are: * Ms Deborah Cope with background in economics regulation processes rural remote service delivery; * Mr James Cox PSM Deputy Chair Australian Energy Regulator extensive experience pricing regulations social policy issues; * Ms Julie Hulcombe PSM allied health reform improving high quality care access Queensland significant contributions; * Dr Lynne Pezzullo market development economic disability sector expertise .

Annual Pricing Review (APR) decision making framework The NDIA monitors reviews its price control frameworks other settings determine appropriateness APR important part process Figure outlines conceptual framework leading final recommendations.

Footnote: Information about NDIA’s Pricing Reference Group can be found here.

18 Page 770of 1049

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Figure 2: APR Conceptual Framework

Research into the following areas provided the quantitative and qualitative aspects of evidence to inform the APR decisions:

  • The current Australian economic climate including the healthcare and disability sectors.* Detailed labour force and wage data for NDIS occupations * an industries,* and comparable occupations.
  • Extensive consultations with a range of internal external stakeholders through the Public Consultation, Pricing Arrangement Reference Group , Pricing Interdepartmental Committee as well as other government engagements .
  • Impact from global pandemic, impact SCHADS Award changes Aged Care reform family domestic violence leave All form part DSW related supports research.
  • Scheme statistics each topic scope (DSW-related supports therapy plan management support coordination). The stats include movements terms participant numbers payments made.
  • Analysing business dynamism topics in scope examining number provider entrants exits general market dynamics.
  • Additional benchmark analysis comparison therapy other government insurance funding schemes private billing rates. All these factors were considered developing 2022-3 APR recommendations ensure decision robust evidence based. This document was released under Freedom Information Act by National Disability Insurance Agency.

Disclosure Log

Domestic economic conditions and the care economy

Outlook

While Australia has Withstood The Impacts Of Global Pandemic It Is Not Immune To Intensifying Challenges While The National Economy Forecast Grow By In ,

Disclosure Log

2022-23 Annual Pricing Review

Internationally, Australian public spending on disability, as captured by the Organization for Economic Cooperation and Development (OECD), sits at 2.% GDP6, ranking it 8th highest among 38 OECD countries. This is higher than Denmark’s <span style=

Disclosure Log

Figure 5: Overall and Health Specific CPI

Overall_and_Health_Specific_CPI Source: ABS Consumer Price Index

Labour market conditions

Australia’s labour market has been resilient with a record low unemployment rate of 3.5% recorded in February 2023. The HCSA industry is the largest employing industry in the economy, employing 2 million persons in February *77. Overall, employment growth within these industries has outpaced that across all other sectors over recent years (Figure <ref id=

Disclosure Log

Strong Employment Growth: HCSA Sector Analysis - Annual Pricing Review for 2022-23

Strong employment growth is a key feature of the HCSA sector—it has been observed that the proportion of persons working within this sector increased from 11.9% to 14%. Factors contributing to these changes include: • The build-up of unmet demand for care services. • Growing demands supported due to population aging, • Continued expansion of NDIS programs; and strong demand specifically related mental healthcare service.*

Figure 7: Percentage Of Workforce In The Healthcare And Social Assistance Sector

Percentage_of_Workforce The chart illustrates an upward trend over time in percentage points representing workforce participation across various years starting at approximately 8 percent around mid-1996 through reaching nearly 14 per cent towards late 2022 with minor fluctuations along its trajectory indicating steady increase year-on-year.

Analysis based on ABS Census data reveals significant job creation between census periods ending December, showing substantial gains particularly among Aged and Disabled Carers (up by +57%), Occupational Therapists (+49%) & Speech Professionals/Audiologists (*+72%). These figures highlight robust hiring trends especially noticeable during recent times as reflected further into figure eight below.

Footnotes: 8There are other professions under ANZSIC’s Health Care & Social Assistance category not directly involved providing direct patient care such accountants/administrators etc., excluded here 9[Productivity Commission Inquiry Report – Mental Health, 2020]

Disclosure Log

Per Cent
Aged and Disabled Carers
Personal Carers and Assistants
Occupational Therapists
Speech Professionals and Audiologists
Health and Welfare Support Workers
Physiotherapists
Welfare Support Workers
Carers and Aides
Nursing Support and Personal Care Workers
Total employment
Source: 2016 & 2021 Census

Mirroring this trend, the number of vacant positions in NDIS related occupations sector is also at record highs indicating strong demand for workers in the sector (Figure). This further highlights the demand for workers in HCSA industry and NDIS more specifically with job vacancies in the industry doubling compared to pre-pandemic levels averaging over , underemployment rate falling to % since .

[Line graph] Source: National Skills Commission (Jobs And Skills Australia) Over years prior pandemic nominal wages were fastest growing all industries. Despite this wage growth slower than price goods services meaning real wages have declined However relative year real wage growth remains above that total real wage growth Trend made challenging some organisations attract retain staff as seek higher wages compensate issue across may be facing not just within disability broader HCSA industry.

Disclosure Log

Future sector demand for support and workforce growth

As the Scheme continues to grow, the importance of a strong workforce to support the growing demand for services is highlighted.

  • The Australian Government projects employment in HCSA sector to grow by 301,**000 (or 15.8%) over the five years to November 2610, the second fastest growth among all [Australian],New Zealand Standard Industrial Classification industries.The Care Workforce Labour Market Study predicts that care-and-support-workforce will reach [3.]%, total employment by ’49-‘50’, up from [2.’]%.in '19-',‘20’^18. The National Skills Commission(now Jobs &Skills Australia) published the 2022 Skills Priority List Key Findings Report October 2022. Many largest care-related occupations by employment were found shortage including Aged or Disabled Carer,Nursing Support Worker PersonalCare Assistant.
    - Several reports project persistent skills shortages future.The CareWorkforceLabourMarketStudyNationalSkillsCommission(Jobs&SkillsAustralia) forecasts shortfall about , across aged disability mental health sectors by 27 '-', blowing out to ,by .Centre Economic Development(CEDA report warns of cumulative shortfall direct age workers by <sub><sup>[11]</sup></sub>.Migration is important pillar supporting workforce.Overseas-born comprise around %of care and support in Australia<sup>12</sup>. For this reason, pandemic associated restrictions could have exacerbated labour shortages economy.However,migration has rebounded strongly likely alleviate existing. In summary these conditions suggest strong demand forward tight labour market which pose challenges businesses finding open positions.

Disclosure Log

MR25/01967 FOI 24/25-2242

DISCLOSURE LOG

Annual Pricing Review: 2022–23

Subsection title: Context

The National Disability Insurance Agency (NDIA) uses the National Disability Insurance Scheme (NDIS) Disability Support Worker (DSW) Cost Model for estimating support delivery hours. Parameters: The DSW cost model simplifies employment-related expenses such as base salary shifts loading superannuation annual leave personal long service employee allowances and operational corporate overheads margin temporary loadings introduced on July 1st to account variable COVID adjustments new SCHADS Award provisions.

Disclosure Log

MR25/01967 FOI 24/25-2242 - Annual Pricing Review for 2022–23

The DSW Cost Model is one factor considered in NDIA price setting along with other factors such as market conditions, the SCHADS Award, minimum wage conditions, mandatory superannuation contributions. Proposed changes are suggested to incorporate new family domestic violence leave reforms introduced from February 2023; see section 4.9.

Applicable industrial award

  • The national award applicable DSWs (Disability Support Workers) under the SCHADS Award ([here](https://www.schadsaward.gov.au) incorporating all amendments up until March redacted)
    • Some workers classified Home Care Employees others Social Community Services employees within this framework;
      • Costs covered operational control provider via parameters taken from Social and Community Services Employee section of the SCHADS Award covering costs directly controlled providers,
  • Providers can employ different skill levels experience meet participant needs:
    • Four types worker cost assumptions: Level [Level], [Level], [Level], & `[Level] This does not mean these only type workers deliver NDIS supports through related services.

Market overview

  • Disability support workers sit Healthcare Social Assistance sector fastest growing industry last years employment accounted for %15%
  • HCSA Industry comprises approximately million people broad range occupations surgeons child carers caution drawing parallels between growth in HCSA industry with DSW workforce.
  • Department of Social Services AlphaBeta provides most recent direct estimate size disability support workforce as ,000 in 2020 representing % total HCSA at time Assuming DSW growth line with HCSA there would be roughly ,000 by start . This is likely lower bound, evidence suggests number grew faster than total HCSA recently. Given skills qualifications transferable across care positions NDIS providers compete aged childcare providers changes demand wages one occupation impact availability other jobs. Analysis major job platforms April redacted shows that average hourly pay DSWs exceed those provided to aged care and childcare workers (Table table_1). Analysis on major online employment platforms same period suggest the average hourly wage paid DSWs exceeds those offered to aged care or childcare workers. The National Workforce Plan: 2021–2025 indicates Aged Disabled Carer Occupation has grown more rapidly within this timeframe compared to broader HCSA industry over similar period.

Agency.

Insurance

Disability

National

Released information:

The act that was

Disclosure Log

Table: Number Of Active Registered Providers By Category From Which They Purchased DSW Supports,

July - December 31 Decembeer 2022

|Category | Support | Number active providersJuly – DecemberNumberactiveprovidersJul y–DecemberPercentageChange| hlamlamalamaalamala|| |—–|——|——————|––––––––––|–| |0145 | High Intensity Daily Personal Activities | 6760 | +12% | |0115 | Assistance with Daily Life Tasks in a Group or Shared Living Arrangement | 3,302 | -21% | |0125 | Participation In Community Social and CivicActivities | 5,965 | -17% | |0107 | DailyPersonalActivities | 680 | -12% | |0106 | AssitanceInCoordinatingorManagingLifeStages TransitionsandSupports | 3,341 | -11% | |0102 | Access And Maintain Employment Or Higher Education | 3.64 | -9% | |0136 | GroupAndCentreBasedActivities | 2 642 | -5% | |0117 | Development OfDailyLiving Skills | 3.053 | -4% | |0133 | Specialised SupportedEmployment | 5-78 | -5% |

Source: NDIS internal administrative data Note: Thedata is not collected from unregistered providers.Providers are duplicated where more than one serviceis provided.

Business Dynamism

To supplement the Scheme statistics,the NDIA hasanalysed registered provider payment activity.That ist,payments made against Agency and Plan Managed plansare considered to be mad by registeredproviders.Figure shows thenumber of registered DSWproviders withthe payments between JulyDecember, splitbythenumbersof half-year periods in which eachprovider received apayment.Half-years defined as six-month intervalfrom Januaryto JuneJuly December.As seenin Figure , out of (32%) registered havepayments all fivehalf yearsbetweenand . These account for % total across period.`

Disclosure Log

MR25/01967 FOI 24/25-2242

Figure 11: Registered DSW Provider Half-Yearly Payments Histogram (June 2020 - December 2022)

Figure Source: NDIS Internal Administrative Data To further assess the current state of the provider market, payment activities of registered providers across a two-year period from January 2021 to December 2022 were analyzed. Preliminary definitions include:

  • Providers with New Activity are those with no previous payments but had at least one during this time frame;
  • Conversely,
  • Providers who became Inactive, having made prior payments yet none within these years; their activity is measured as percentages relative either total payments in said half year or preceding periods for comparison purposes. The NDIA acknowledges that while not perfect due limitations on data availability—this method provides an approximation closest available measure towards understanding exits and transitions among service delivery networks over specified intervals. Results indicate inactive registered providers contributed less than 3%, whereas new entrants accounted between approximately * ext{1.1 extendash{}1.5} extpercent* of overall expenditures throughout both observed durations.

DISCLOSURE LOG

Ability Roundtable benchmarking survey

Ability Roundtable conducts a comprehensive benchmarking survey. In 2023, 24 providers responded to this survey using data for financial year **2021-22***. Not all respondents answered every question available; thus, usable sample sizes varied on each topic (SCHADS Award changes, COVID impacts, Quality Safeguarding Compliance costs). Although there were fewer total responding providers than expected due to smallness in provider base servicing large part disability market which should considered when interpreting results.* The collective revenue was over $$2{.}7 billion$, with average respondent reporting an operating loss $of \textbf{{}}${3}{ {. }} { } ${}$%. In summary, information received from ability round table will further discussed within chapter* such as COVID and SCHADS related adjustments driving up cost magnitude similar considerations that informed temporary loading granted from APR.`

Cost Impact Of COVD`

Impact analyzed through economic research along with ability round table survey. in 2021-22 APR impact of COVID estimated continue increase medium long term*. Base costs associated PPE additional overtime or leave usage at time would increase by .5%$. Considered price rise DSW from the 9% price rise. Domestic economic research since last APR HCSA sector best proxy performed relatively well during pandemic compared other sectors Australia Businesses classified essential such workers continued providing critical healthcare support services community challenges disruptions service delivery lockdowns restrictions able adapt new ways working telehealth virtual consultations That said, businesses care economy faced increasing COVID-related costs Temporary included those associated PPE mandates testing requirements establishing new ways working such telehealth associated overtime greater utilization sick leave However States Territories have now lifted public health orders directives mandats on business majority ending late **or early*. Accordingly some Government COVID orders such as PPE gear*, and testing dissipated Nevertheless ongoing referred several submissions consultation is cost sick leave staff contracting rostering cover sick staff Although providers experienced supply chain disruption majority NDIS labour intensive reliant upon goods capital equipment hence modest $\textbf{{}}${$} { } ${}$%.

DISCLOSURE LOG

MR25/01967 FOI 24/25-2242

Disclosure Log: Annual Pricing Review for 2022–23

Disruptions: Compared with disruptions affecting all businesses at an estimated rate of about 41%, many care economy enterprises experienced difficulties finding staff during June both years (June ’21 and June ‘22) – specifically noted were issues related to job applicants’ lack thereof (79%) or insufficient qualifications (*59%). These trends are likely linked primarily due to reduced migration over Q2 & Q3, which historically has been crucially important in providing disability workers but now shows signs rebounding towards pre-pandemic levels.

Ability Roundtable survey on continuing impact COVID on provider costs:

Most respondents (around 71%) reported that their organizations still faced cost increases from COVID as recently as early this year; however a smaller portion indicated no longer experiencing such impacts ( extbf{~}29%). The average increase among those reporting ongoing effects was approximately extit{ extcolor[rgb]{0,.8}{2.5}}%, while the median figure stood slightly lower around ~* extit{ extcolor[rgb]{0:.8}.} % .* Across other providers who provided estimates regarding these changes, he mean rise across all responses amounted roughly to 1.7%; whereas medians fell closer toward 1%. Unlike SCHADS Award modifications and Quality Safeguard compliance expenses—both of which tend more consistently with long-term implications—the qualitative feedback suggests most COVID-related financial burdens have proven temporary rather than enduring. Common causes cited for increased expenditures included PPEs, rapid antigen tests (RAT), consumables (30%) alongside staff sick leave claims (*20%), administrative overheads like cleaning services or agency staffing arrangements accounting collectively between *5–*10%. Another small proportion attributed additional spending towards training programs, quality assurance measures, etc., likely reflecting recurring operational needs.

In summary: The estimated impact on costs due primarily by COVID in Q4’22, based upon survey data from participating organizations is projected at about 1-2 percentage points higher compared against prior assessments made during last year’s Annual Pricing Review (APR). The evidence indicates that many cost increases associated directly linked back specifically to pandemic conditions are now diminishing post-pandemic era; however it remains clear that the virus continues its presence albeit significantly lessened intensity relative levels observed earlier this past calendar period.

Impact of SCHADS Award Changes:

on July extit{ extcolor[rgb]{0,.8}{ .}}, several significant alterations were introduced into the framework governing pay rates and working hours within Australia’s Disability Support Services sector. Specifically, he new rules granted casual & part-time workers a minimum two-hour shift duration along with other adjustments such as enhanced compensation allowances for broken shifts plus provisions related to call-out duties/remote work opportunities. Despite these modifications being implemented relatively recently,* there has been limited quantitative feedback available regarding their overall effect thus far—primarily confined only qualitative insights gathered through surveys conducted via Ability Roundtable benchmarking studies. Accordingly,62% respondents reported increased staffing requirements necessitated following implementation of changes, whereas another smaller portion (**~ 37%) indicated reduced workforce numbers due instead.

Two-thirds ( extbf{two thirds})* stated they experienced elevated operational costs because resultantly from adopting revised terms under the aforementioned award scheme; evertheless one-third noted no discernible increase in expenses attributable thereto.

Disclosure Log

MR25/01967 FOI 24/25-2242

2022–23 Annual Pricing Review

For those respondents reporting cost increases from the SCHADS Award changes, the average cost increase was 2.4%, and the median 2.0%. (One statistical outlier was removed.) Across all respondents, the average cost increase was 1.5 (median **). It should be considered in the context of these survey respondents as they may not represent an accurate representation of the overall NDIS market; however this is still valuable data. It’s important that we distinguish between one-off adjustment costs when implementing a change versus ongoing costs incurred thereafter: most common comment (33) on why increased following SChADs award were one-offs such purchasing new software retraining current employees rules changing rosters Conversely small minority (18) mentioned minimum two-hour shift requirement which permanent change In summary Ability Roundtable indicates estimated impact Schads Awards provider costs average impact total costs similar to what anticipated APR Considered much borne providers likely one off adjustments to Schads Award changes.

Increases superannuation contributions From July employer superannuation contribution will rise wages .20

Using DSW Cost Model NDIA estimates this superannuation contribution raise standard hour disability support worker supports $62 17$ $62 .45, or %.

Impact domestic family leave reforms Australian Government introduced paid family violence leave for all employers across Australia February employees non-small business can access days paid family and domestic violence leave period Employees small businesses able same family domestic violence entitlement August available full-time part-time casual employees pro-rated. For more information see Fair Work Ombudsman’s Family Domestic Violence Leave page

As determined by Australian Tax Office

Annual Pricing Review

Previous surveys and studies provide a useful reference point, with an estimate take up of family and domestic violence leave ranging from approximately 0.05 percent to about 0.8 percentage points among all employed individuals. See Appendix B in detail regarding more information on how the National Disability Insurance Agency (NDIA) reviewed data concerning prevalence rates related specifically towards domestic abuse alongside conducted investigations into utilization patterns within Australia’s workforce that pertain directly toward such leaves being taken.

DISCLOSURE LOG

2022-23 Annual Pricing Review

This matching is based on the type of work generally performed by this type of worker “personal care tasks by a ‘personal care worker grade 3’”” personal care support provided require working under limited supervision.Further,theAgedCareAwardlevelworkercanrequireaCertificateorhigherwhilethesCHADSAwardLevelworkerrquireacertificateoreigher[2pt]�ComparisonofthesesAwardworkerwageshighlightsthedifferencethatexistsbetweenthetwoAwards.FromJulyforaweekdaydaytimehourly wage,thefullandparttimSCHAADSawardLeflerecordedpaypointis$per hour whilethetimAgedcareawardefinedasrecordedpaypointis$per hour Thiscurrentlyequates toadiffrenceof$per hour,orthesACHASLevelemployeewareratebeing% higher.ThiscurrentwagedifferentialmeanswiththeadincreasetotheAged Careworkersitwilllikelyseethegapnarrowbetweenthesectionswithdisability workersstillhigheby$per hour or%.Therearealsonon-wage reformsongoingintheAgedCaresectoraimedinprovingqualityofofare. ThesemayhaveflowimpactsuponavailableworkforceNDISparticipants and the disability sector more broadly but again then DIA expects impact be limited More information about these potential impacts on NDIS canbe found in Appendix C OverallthenDIAacknowledgesthatthead increase Aged care worker wages otherreforms being undertaken aged are expected make working agecaressectorrelativelymoreattractive than previously On balance,theNDAIanticipatesthis is unlikely have majorimpact cost similarly skilled workersbut workforce availability should continue monitored as reformed rolled out

Temporary Transformation Payment “TTP” for manydisability support workrelated supports introduced July to assist providers transitioning businesses into NDIStansitional price levels represent necessary attract new document[3pt]�SCHADSawardcanaccessedhere(incorporatingallamendmentsupincludingMarch ) FairWorkOmbudsmanpayguidesFor exampleimprovementsAgedCareQualityStandardswhich canbefound here

Disclosure Log

2022–23 Annual Pricing Review

providers to enter the market or reduce exits from the market. They represent price levels above sustainable but should be adopted where significant expansion needed. The base prices set since July have been aligned estimated efficient costs delivery TTP loading used adjust these transition level initially equal difference between and average cost over time providers became more efficient. Providers can claim following groups supports:

  • Access Community Social Recreational Activities
  • Assistance With Self-Care Activities
  • Group Activities
  • Supports in Employment. Given there are different lines related TTP specific limits pricing arrangements published on NDIS website Scheme statistics In six months December active servicing participants claiming funding Over same period payments made services amount decreased per provider Table below illustrates scheme statistics TABLE 4: TEMPORARY TRANSFORMATION PAYMENT SCHEME STATISTICS Source: NDIS internal administrative data As reported APR report a number claimed did not meet eligibility requirements Only completed benchmarking survey financial year percent completion first half of second financial year

Disclosure Log

MR25/01967 FOI 24/25-2242

DISCLOSURE LOG

2022–23 Annual Pricing Review

These numbers signalled there was a low response rate. The results suggest using TTP (Text-to-Prompt) current form encourages take-up financial benchmarking survey not successful anticipated collate information on provider’s bottom line financially.

Feedback from consultations

Of submissions received, % discussed disability support worker related supports. one main themes raised: is still ongoing adjustments many providers quality safeguards compliance COVID SCHADS Award changes. costs among support workers delivering skills variance generally paid NDIS price limit. delivering participants also felt wide variances in these workers were at NDIS price limit. supplies See Appendix A more details common themes raised submissons Consultation Paper APR .

Recommendations

In determining DSW-related limits labour market care sector remains tight conditions could potentially intensify competition terms with other sectors put pressure supply forward going. to ensure participant wellbeing safety it considered appropriate pass minimum wages national employment standard superannuation occur for this to happen.

  • Recommendation The NDIA subject specific recommendation arising current Annual should increase the price limits determined by Disability Support Worker Cost Model July reflect any changes specified Social Community Home Care and Industry 2010 following Fair Work Commission’s Wage Review Superannuation Guarantee Charge. The temporary loading introduced July intended assist providers adjust costs such as COVID and SCHADS Award changes. Considerations have been given: • It recognized that restrictions economy wound back However active Australia likely continue disrupt supports delivered NDIS participants Providers incur some PPE RAT tests when arise (such).• Appears one-off needed Adjustments made recently major Awards are relatively recent Sector vulnerable groups community impacts somewhat slower rest nation. Recognizes cost impact borne providers time fully systems processes major awards changes can still be taken.

DISCLOSURE LOG

MR25/01967 FOI 24/25-2242

Disclosure Log: Annual Pricing Review (2022–23)

The National Disability Insurance Agency (NDIA) has considered that most costs have been addressed or reduced over past years due primarily to COVID-related expenses which are now decreasing post-pandemic alongside one-off adjustments made following changes to SCHADS Award rates. However, it acknowledges these potential impacts could affect participant safety because some providers still face transition costs associated with both issues mentioned above; hence extending temporary loadings for an additional twelve months at a rate of $1 ext{ per cent}$ effective January (\mathrm{{JULY}}~{}_{2}^{o}), ceasing this adjustment in June next year, allowing more time before full implementation is expected.

DISCLOSURE LOG

Recommendation

2022–23 Annual Pricing Review

The NDIA will continue to work closely with the sector in monitoring market conditions and cost structures in the absence of a NDIS Financial Benchmarking Survey.

Recommendation 5:

The NDIA should maintain its current pricing strategy including the scheduled reduction over the next year of the Temporary Transformation Payment (TTP) loading to 1% on July, one thousand twenty-three (JULY). The TTP loading should cease from applying as-of July first(JULY) two-thousand二十四(TWENTYFOUR).

  • The NDIA is allowed registered providers who have been claiming for the TTP within financial years two-twenty-two through twentytwo thirtythree(THIRTYTHREE) until cessation.CESSION to do so continuing into fiscal year three-fourthirtytwo threetwentyfour(THREETHIRTWOFORTYFIVE) until termination.

Disclosure Log

Therapy Supports

Context

Therapy supports are important to participants and to the NDIS. They assist participants to build capacity to achieve their goals, an they have potential to reduce long term costs within NDIs as they can help improve capacities over time. The therapy services available include Art Therapists, Audiologists Counsellors Developmental Educators Dietitians Exercise Physiologists Music Therapists Occupational Therapists Orthoptists Physiotherapists Podiatrists Psychologists Rehabilitation Counselors Social Workers Speech Pathologists. These therapies may also be provided under supervision from a therapist’s delegation at all times where an assistant is used in providing support; this must comply professional indemnity insurance requirements set forth above. Within most cases these three groups provide:

  • Therapeutic Support (018): a mix that helps individuals aged seven years or older with functional skills such as language communication personal care mobility movement interpersonal interactions community living;
  • Early Intervention for Early Childhood (0126):a combination of therapeutic activities along key workers aimed towards children between zero six years old who suffer developmental delays disabilities helping them reach better outcomes regardless diagnosis;
  • Exercise Physiology & Personal Well-being Activities: physical well being promoting exercise among others.

In addition therapists deliver supports through other registration categories including:

  • Specialist Positive Behaviour Support (0135) includes items by allied health professionals specializing positive behavior assessment and development plans to reduce concerning behaviors, custom prostheses orthoses requiring specialist knowledge within 0147 category, specialized hearing services catered toward complex needs adults and kids alike, as well as general Hearing Services catering both age ranges.

DISCLOSURE LOG

MR25/01967 FOI 24/25-2242 Annual Pricing Review: 2022–23

There are currently 14 different therapy support items within the Capacity Building Support Categories. These supports can be delivered to individual participants or groups, with hourly price limits divided among group members if provided collectively; they do not vary based on time but may differ across states/touritories depending upon who delivers them—therapists like Art therapists, Audiologists,…and other professionals such as Counsellors… as well as direct service provision, Therapists claim for Non-Face-to-Face Provision, Provider Travel, Short Notice Cancellations & NDIA Requested Reports…they can also account for non-labour costs associated with travel claims. As Table included below shows there exist separate pricing caps per provider type: •Art therapists,Audiologists,Dietitians…,Occupational Therapists,,Orthoptists,Podiatrists,Social Workers.,Speech Pathologists and Other Professionals •Counsellors •Exercise Physiologists •Psychologists •Physiotherapists •Therapy Assistants.[2ex] Seven (of these) seven of those therapies appear in duplicate under Activities Daily Living Core Category; The Exercise Physiologist and Dietitian’s services are duplicated again into Improved Health Wellbeing Capacity Building Support Category.

Disclosure Log

TABLES: Pricing Limits and Scheme Statistics

Table 5 - Price limits per therapy type:

| Type | NSW/VIC/QLD/ACT | SA/WA/TAS/NT | Remote | Very remote | |-|-|-|-| | Art Therapists | $193.99 | $193.99 | $271.59 | $290.99 | | Audiologists | $193.99 | $193.99 | $271.59 | $290.99 | … (rest omitted due to length)

This chapter examines pricing arrangements for NDIS Therapy Supports, including alignment with comparable schemes.

Section 5.2 Schemes’ statistics show a rise in participants from December ’22 compared year-on-year.

Disclosure Log

2022–23 Annual Pricing Review

| Statistics | July – December \n\t \t   2021 | July -December\ nbsp;    2022 | Percentage Change | |-:|–:-||–::––| | Numberof active unregistered providerso f Therapy supports | $32{comma}133$ | $38{comma}14$⁥ | +1% | Average amount claimedby allactiveproviders o fTherapysupports | $ ext{€}$3,67⁥ | $ ext{€} ext{}$,947$ |+${}%$$ | Totalamountclaimedb y registeredprovidersOf Therapysuppor ts | $ ext{} extbf{{}}$.9 billion | $ ext{} extbf{{}.}{},16$billion | ${}%+ extbf{{ }}+$ | Averag e amoun t clai med by registe redp roviders of Th er apy suppo rts | $ ext{} extbf{{.}}{{}}}. extbf{{{ }},{ } extbf{{{ }}}}${}&$ extbf{{{ .}}}\textbf{{{ \space {)}}}| \textbf{{{ .$}}}.$ extbf{{{ ,}}}0, extbf{{{ 738}}}$ &nb sp;   | | T otal a mout c laimed b unregistered providerso f Therapy supports | $ ext{}.29 $billi on | $ ext{.,} {.}.{ },$⁥bil lion | +% | Average amount claimedbyunregis teredproviders o fTherapysupports | $ ext{},0,43$ | $ ext{€} ext{}$,790$ |+${}%$$

Source: NDIS internal administrative data Note: Please note the numberof ‘active registeredprovidersOf Therapysuppor ts andnumber’of active’unregistere d prov id ers OfT hera py su pport s’donot align withthe totalnum berO fo f’the activ e pro viders’. There are two reasonsfor this:

  1. One providercan provide multiple supportswithbeing regist er ed for sometypes ofsupport providedand unregisterdforeither (different registration groups )inthesame period so theyare accountedf or inbothgroups Ofo fp roviders ;
  2. Providerswiththeknownregistrationar ecapturedintotalamountsbutnotpresentedinthis tableastheymakeupthans 1%oftota l payments. Figure (\underline{{}}. below shows the quarterly breakdowno fscheme expenditureont hera peutic supportsan dp r op ortionso ft he overall schemeexpenditure.Therapeutic suppo rt smake $9{.%}or$ ext{} extbf{{{ }}$.817, extbf{{{ .}}}million oft otal schemecostsin thethree months toDecember,022.Asshown on chart above , thesesupportshoveraround$%.4% o f t het ot al Scheme costsfort helast quarters **FIGURE **⁥: NDIS EXPENDITUR ON THERAPY SUPPORTS SINCE DECEMBER 2020 QUARTER RELATIVE TO TOTALNDIS EXPEND IT URE | $ ext{}Mill ion | Totalpayments | PercentageofTotalScheme | |-:-|–::-||–::––| |$301.{ }m&nb sp;  &$9. ${}&$9,&nb s p;. ${} ext{%}$ | \text{$}{},.$ ext{€}. { } ext{ m}| \\text%$$ | DecQtr\n\t \t 2020 | Mar Q tr\ntxt 2021 | Jun Qt r\ntxt $2021$ | SepQt r\ntxt 2021 | Dec Qt rt xt 2021 | Ma rq trtxt 2022 | June Qt txt 2022 | Se q t rtxt 2022 | De c Qt r$\n\t texttt{2}022$

Source: NDIS internal administrative data

ParticipantsFrom the participantswith a claimfor therapy supportsfrom their planinthe sixmonthstoDecember, ,themost commontherapist supportis for“Other Professionals”($254, extbf{{{.}}}millionclaimed), followed by Occupational Therapists (fors80. extbf{{}} million claimed)

Disclosure Log

2022–23 Annual Pricing Review and Physiotherapy ($$467 million). Noting participants can use more than type therapy.

Table 7: Scheme Expenditure By Type Of Therapy July To December 2022 | Number of Participants | Number of Providers | Total Amount Claimed |

| — | — | — | — | | Occupational Therapists | $532 m | (m ext{)} | $egin{matrix} extbf{ extit{(Table 7)}} & extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B}} extbf{ extit{A}} extbf{ extit{L}} extbf{ extit{Y}} extbf{ extit{: S} extbf{ extit{C}}} && extbf{ extit{H}} extbf{ extit{M}} extbf{ extit{E}} extbf{ extit:X} extbf{ extit{P}} extbf{ extit{EN}} extbf{ extit{DIT}} extbf{ extit{U}} extbf{ extit{R}}}& extbf{ extit{E}}\ extbf{ extit{S}} extbf{ extit{K}} extbf{ extit{I}} extbf{ extit{N}} extbf{ extit{G}}, extbf{ extit{O}} extbf{ extit{F}} extbf{ extit{T} } extbf{ extit{H}} extbf{ extit{E }} & extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B}} extbf{ extit{A}} extbf{ extit{L}} extbf{ extit{Y}} extbf{ extit{: S} extbf{ extit{C}}} && extbf{ extit{H}} extbf{ extit{M}} extbf{ extit{E}} extbf{ extit:X} extbf{ extit{P}} extbf{ extit{EN}} extbf{ extit{DIT}} extbf{ extit{U}} extbf{ extit{R}}}& extbf{ extit{(Table 7)}}\ extbf{ extit{S}} extbf{ extit{k}} extbf{ extit{i}} extbf{ extit{n}} extbf{ extit{g}}, extbf{ extit{o f t h e }s c k i n g, o f} \ extbf{ extit{s k i n g}, of the sking)} & extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B}} extbf{ extit{A}} extbf{ extit{l y: s C }} && extbf{ extit{h M E X P EN D IT UR}})& extbf{ extit{(T a b l e T )}}} \ extbf{ extit{e}} extbf{ extit{x p en d it ur))}\ extbf{ extit{t ab le T) }}} extbf{ extit{a b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{b la }} extbf{ extit{(T a b l e T )}}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y: S C H M E X P EN D IT UR)}} & extbf{ extit{s k i n g, o f the sking)} \ extbf{ extit{n s k i ng, of t he sk ing))}\ extbf{ extit{k in g)))} extbf{ extit{i ng))))} \ extbf{ extit{l y: s c h m e x p en d it ur}))}& extbf{ extit{t ab le 7) }}} extbf{ extit{a bl a }} extbf{ extit{bl a }} extbf{ extit{bl a }} extbf{ extit{bl a }} extbf{ extit{bl a }} extbf{ extit{bl a }} extbf{ extit{bl a }} extbf{ extit{bl a }} extbf{ extit{bl a }} extbf{ extit{bl a }} extbf{ extit{(T a b l e T )}}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y: S C H M E X P EN D IT UR)}} & extbf{ extit{s k i n g, o f the sking)} \ extbf{ extit{n s kin g))}\ extbf{ extit{k in g)))} extbf{ extit{i ng))))} \ extbf{ extit{l y: sc h m e x p en d it ur}))}& extbf{ extit{t ab le 7) }}} extbf{ extit{a bl a }} extbf{ extit{b la }} extbf{ extit{bla }} extbf{ extit{bl a }} extbf{ extit{bl a }} extbf{ extit{bl a }} extbf{ extit{bl a }} extbf{ extit{bl a }} extbf{ extit{bl a }} extbf{ extit{bl a }} extbf{ extit{(TableT)}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{BALY :SCHMEXPENDITUR}}} & extbf{ extit{s k ing, of t he skin g))}\ extbf{ extit{n skin g))}\ extbf{ extit{k i n g)))} extbf{ extit{i ng))))}) \ extbf{ extit{l y:s c h me exp endi tur))} } extbf{ extit{tab l e T ) } })}& extbf{ extit{abla abla abla abla abla abla abla abla abla abla (Tabl et) }}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y: S C H M E X P EN D IT UR)}}, extbf{ extit{o f the sking}))}\ extbf{ extit{n s kin g))}\ extbf{ extit{(TableT)}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{BALY :SCHMEXPENDITUR)}, o fthe sk in g)) & extbf{ extit{s k ing, of t he skin g))}\ extbf{ extit{n skin g))}\ extbf{ extit{k i n g)))} extbf{ extit{i ng))))}) \ extbf{ extit{l y:s c h me exp endi tur))} } extbf{ extit{tab l e T ) } })}& extbf{ extit{abla abla abla abla abla abla abla (Tabl et) }}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y: S C H M E X P EN D IT UR)}},ofthesk in g)) & extbf{ extit{s k ing, of thesking}))}\ extbf{ extit{n s kin g))}\ extbf{ extit{(TableT)}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{BALY :SCHMEXPENDITUR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}\ extbf{ extit{n skin g))}\ extbf{ extit{k i n g)))} extbf{ extit{i ng))))}) \ extbf{ extit{l y:s c h me exp endi tur))} } extbf{ extit{tab l e T ) } })}& extbf{ extit{abla abla abla (Tabl et) }}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y: S C H M E X P EN D IT UR)}},ofthesk in g)) & extbf{ extit{s k ing of thesking}))}\ extbf{ extit{n s kin g))}\ extbf{ extit{(TableT)}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{BALY :SCHMEXPENDITUR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}\ extbf{ extit{n skin g))}\ extbf{ extit{k i n g)))} extbf{ extit{i ng))))}) \ extbf{ extit{l y:s c h me exp endi tur))} } extbf{ extit{tab l e T ) } })}& extbf{ extit{abla abla a b la (Tabl et) }}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y: S C H M E X P EN D IT UR)}},ofthesk in g)) & extbf{ extit{s k ing of thesking}))}\ extbf{ extit{n s kin g))}\ extbf{ extit{(TableT)}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{BALY :SCHMEXPENDITUR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}\ extbf{ extit{n skin g))}\ extbf{ extit{k i n g)))} extbf{ extit{i ng))))}) \ extbf{ extit{l y:s c h me exp endi tur))} } extbf{ extit{tab l e T ) } })}& extbf{ extit{abla abla a b la (Tabl et) }}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y: S C H M E X P EN D IT UR)}},ofthesk in g)) & extbf{ extit{s k ing of thesking}))}\ extbf{ extit{n s kin g))}\ extbf{ extit{(TableT)}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{BALY :SCHMEXPENDITUR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}\ extbf{ extit{n skin g))}\ extbf{ extit{k i n g)))} extbf{ extit{i ng))))}) \ extbf{ extit{l y:s c h me exp endi tur))} } extbf{ extit{tab l e T ) } })}& extbf{ extit{abla abla a b la (Tabl et) }}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y: S C H M E X P EN D IT UR)}},ofthesk in g)) & extbf{ extit{s k ing of thesking}))}\ extbf{ extit{n s kin g))}\ extbf{ extit{(TableT)}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{BALY :SCHMEXPENDITUR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}\ extbf{ extit{n skin g))}\ extbf{ extit{k i n g)))} extbf{ extit{i ng))))}) \ extbf{ extit{l y:s c h me exp endi tur))} } extbf{ extit{tab l e T ) } })}& extbf{ extit{abla abla a b la (Tabl et) }}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y: S C H M E X P EN D IT UR)}},ofthesk in g)) & extbf{ extit{s k ing of thesking}))}\ extbf{ extit{n s kin g))}\ extbf{ extit{(TableT)}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{BALY :SCHMEXPENDITUR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}\ extbf{ extit{n skin g))}\ extbf{ extit{k i n g)))} extbf{ extit{i ng))))}) \ extbf{ extit{l y:s c h me exp endi tur))} } extbf{ extit{tab l e T ) } })}& extbf{ extit{abla abla a b la (Tabl et) }}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y: S C H M E X P EN D IT UR)}},ofthesk in g)) & extbf{ extit{s k ing of thesking}))}\ extbf{ extit{n s kin g))}\ extbf{ extit{(TableT)}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{BALY :SCHMEXPENDITUR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}\ extbf{ extit{n skin g))}\ extbf{ extit{k i n g)))} extbf{ extit{i ng))))}) \ extbf{ extit{l y:s c h me exp endi tur))} } extbf{ extit{tab l e T ) } })}& extbf{ extit{abla abla a b la (Tabl et) }}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y: S C H M E X P EN D IT UR)}},ofthesk in g)) & extbf{ extit{s k ing of thesking}))}\ extbf{ extit{n s kin g))}\ extbf{ extit{(TableT)}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{BALY :SCHMEXPENDITUR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}\ extbf{ extit{n skin g))}\ extbf{ extit{k i n g)))} extbf{ extit{i ng))))}) \ extbf{ extit{l y:s c h me exp endi tur))} } extbf{ extit{tab l e T ) } })}& extbf{ extit{abla abla a b la (Tabl et) }}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y: S C H M E X P EN D IT UR)}},ofthesk in g)) & extbf{ extit{s k ing of thesking}))]\ extbf{ extit{n s kin g))}\ extbf{ extit{(TableT)}} \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{BALY :SCHMEXPENDITUR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}]$egin{matrix}$467 million). Noting participants can use more than type therapy.

Table 7: Scheme Expenditure By Type Of Therapy July To December 2022 | Number of Participants |

| — | —| | Occupational Therapists | $532 m | Other Professionals | $egin{matrix} extbf{ extit{(Table T )}}} \ extbf{ extit{l y:s c h me exp endi tur)))} extbf{ extit{tab l e T) }}}$m | Early Childhood | $egin{matrix} extbf{ extit{(Tabl et)} } extbf{ extit{a bl a }} extbf{ extit{b la abla abla (Tabl et) } })}& extbf{ extit{n s kin g}))}\ \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y :S C H M E X P EN D IT UR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}]$egin{matrix}$467 million). Noting participants can use more than type therapy.

Table 7: Scheme Expenditure By Type Of Therapy July To December 2022 |

| Number of Participants| | — || Occupational Therapists | $532 m | Other Professionals | $egin{matrix} extbf{ extit{(TableT)}} \ extbf{ extit{l y:s c h me exp endi tur)))} extbf{ extit{tab l e T ) }}}$m | Early Childhood | $egin{matrix} extbf{ extit{(Tabl et)} } extbf{ extit{a bl a }} extbf{ extit{b la abla (Tabl et) } })}& extbf{ extit{n s kin g}))}\ \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y :S C H M E X P EN D IT UR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}]$egin{matrix}$467 million). Noting participants can use more than type therapy.

Table 7: Scheme Expenditure By Type Of Therapy July To December 2022 |

| Number of Participants| | — || Occupational Therapists | $532 m | Other Professionals | $egin{matrix} extbf{ extit{(TableT)}} \ extbf{ extit{l y:s c h me exp endi tur)))} extbf{ extit{tab l e T ) }}}$m | Early Childhood | $egin{matrix} extbf{ extit{(Tabl et)} } extbf{ extit{a bl a }} extbf{ extit{b la abla (Tabl et) } })}& extbf{ extit{n s kin g}))}\ \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y :S C H M E X P EN D IT UR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}]$egin{matrix}$467 million). Noting participants can use more than type therapy.

Table 7: Scheme Expenditure By Type Of Therapy July To December 2022 |

| Number of Participants| | — || Occupational Therapists | $532 m | Other Professionals | $egin{matrix} extbf{ extit{(TableT)}} \ extbf{ extit{l y:s c h me exp endi tur)))} extbf{ extit{tab l e T ) }}}$m | Early Childhood | $egin{matrix} extbf{ extit{(Tabl et)} } extbf{ extit{a bl a }} extbf{ extit{b la abla (Tabl et) } })}& extbf{ extit{n s kin g}))}\ \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y :S C H M E X P EN D IT UR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}]$egin{matrix}$467 million). Noting participants can use more than type therapy.

Table 7: Scheme Expenditure By Type Of Therapy July To December 2022 |

| Number of Participants| | — || Occupational Therapists | $532 m | Other Professionals | $egin{matrix} extbf{ extit{(TableT)}} \ extbf{ extit{l y:s c h me exp endi tur)))} extbf{ extit{tab l e T ) }}}$m | Early Childhood | $egin{matrix} extbf{ extit{(Tabl et)} } extbf{ extit{a bl a }} extbf{ extit{b la abla (Tabl et) } })}& extbf{ extit{n s kin g}))}\ \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y :S C H M E X P EN D IT UR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}]$egin{matrix}$467 million). Noting participants can use more than type therapy.

Table 7: Scheme Expenditure By Type Of Therapy July To December 2022 |

| Number of Participants| | — || Occupational Therapists | $532 m | Other Professionals | $egin{matrix} extbf{ extit{(TableT)}} \ extbf{ extit{l y:s c h me exp endi tur)))} extbf{ extit{tab l e T ) }}}$m | Early Childhood | $egin{matrix} extbf{ extit{(Tabl et)} } extbf{ extit{a bl a }} extbf{ extit{b la abla (Tabl et) } })}& extbf{ extit{n s kin g}))}\ \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y :S C H M E X P EN D IT UR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}]$egin{matrix}$467 million). Noting participants can use more than type therapy.

Table 7: Scheme Expenditure By Type Of Therapy July To December 2022 |

| Number of Participants| | — || Occupational Therapists | $532 m | Other Professionals | $egin{matrix} extbf{ extit{(TableT)}} \ extbf{ extit{l y:s c h me exp endi tur)))} extbf{ extit{tab l e T ) }}}$m | Early Childhood | $egin{matrix} extbf{ extit{(Tabl et)} } extbf{ extit{a bl a }} extbf{ extit{b la abla (Tabl et) } })}& extbf{ extit{n s kin g}))}\ \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y :S C H M E X P EN D IT UR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}]$egin{matrix}$467 million). Noting participants can use more than type therapy.

Table 7: Scheme Expenditure By Type Of Therapy July To December 2022 |

| Number of Participants| | — || Occupational Therapists | $532 m | Other Professionals | $egin{matrix} extbf{ extit{(TableT)}} \ extbf{ extit{l y:s c h me exp endi tur)))} extbf{ extit{tab l e T ) }}}$m | Early Childhood | $egin{matrix} extbf{ extit{(Tabl et)} } extbf{ extit{a bl a }} extbf{ extit{b la abla (Tabl et) } })}& extbf{ extit{n s kin g}))}\ \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y :S C H M E X P EN D IT UR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}]$egin{matrix}$467 million). Noting participants can use more than type therapy.

Table 7: Scheme Expenditure By Type Of Therapy July To December 2022 |

| Number of Participants| | — || Occupational Therapists | $532 m | Other Professionals | $egin{matrix} extbf{ extit{(TableT)}} \ extbf{ extit{l y:s c h me exp endi tur)))} extbf{ extit{tab l e T ) }}}$m | Early Childhood | $egin{matrix} extbf{ extit{(Tabl et)} } extbf{ extit{a bl a }} extbf{ extit{b la abla (Tabl et) } })}& extbf{ extit{n s kin g}))}\ \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y :S C H M E X P EN D IT UR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}]$egin{matrix}$467 million). Noting participants can use more than type therapy.

Table 7: Scheme Expenditure By Type Of Therapy July To December 2022 |

| Number of Participants| | — || Occupational Therapists | $532 m | Other Professionals | $egin{matrix} extbf{ extit{(TableT)}} \ extbf{ extit{l y:s c h me exp endi tur)))} extbf{ extit{tab l e T ) }}}$m | Early Childhood | $egin{matrix} extbf{ extit{(Tabl et)} } extbf{ extit{a bl a }} extbf{ extit{b la abla (Tabl et) } })}& extbf{ extit{n s kin g}))}\ \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y :S C H M E X P EN D IT UR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}]$egin{matrix}$467 million). Noting participants can use more than type therapy.

Table 7: Scheme Expenditure By Type Of Therapy July To December 2022 |

| Number of Participants| | — || Occupational Therapists | $532 m | Other Professionals | $egin{matrix} extbf{ extit{(TableT)}} \ extbf{ extit{l y:s c h me exp endi tur)))} extbf{ extit{tab l e T ) }}}$m | Early Childhood | $egin{matrix} extbf{ extit{(Tabl et)} } extbf{ extit{a bl a }} extbf{ extit{b la abla (Tabl et) } })}& extbf{ extit{n s kin g}))}\ \ extbf{ extit{T}}& extbf{ extit{J}}\ extbf{ extit{E}}&& extbf{ extit{B A L Y :S C H M E X P EN D IT UR)}, o fthe sk in g)) & extbf{ extit{s k ing, t he skin g))}]$egin{matrix}$467 million). Noting participants can use more than type therapy.

Table 7: Scheme Expenditure By Type Of Therapy July To December 2022 |

| Number of Participants| | — || Occupational Therapists | $532 m | Other Professionals | $egin{matrix} extbf{ extit{(TableT)}} \ extbf{ extit{l y:s c h me exp endi tur)))} extbf{ extit{tab l e T ) }}}$m | Early Childhood | $egin{matrix} extbf{ extit{(Tabl et)} } extbf{ abular{|c||{1}{>{ aggedright eset@font iny}|r}{}{{8}{p{.9cm}}} {TypeofTherapist}&NumberOfParticipants&NumberOfProviders&TotalsAmountClaimed










































































































































































































































































































































































































































































































































































































































































































































































































































































































































































































































\ \textbf{ extit{t ab le 7) }}} abular{|c||{1}{>{ aggedright abular {|c| * {8} |p {.9cm}}

DISCLOSURE LOG

2022-23 Annual Pricing Review

Providers

As seen in Table 7 above, there were 46,434 providers who claimed for therapy services during six months ending December, 2022. Among them, The therapist with highest number claiming these supports is Other Professionals (25,**544), Psychologist(11, **631) ,

  •   Early Childhood professionals delivering Early childhood supports*(10*,***362)and Physiotherapist *(10*,***249).*

In comparison between Dec.,’22 & Dec.‘21: There was a rise from $8,,*900 registered provider delivering Therapy service compared to $8,,,833. However, in terms of claims made by providers within six month period ended Dec.’, ‘22. The total amount claimed was $****1,billion which increased upfrom$*990 million recorded earlier in Dec’, ‘21’. This represents drop in proportion being paid to Registered Provider as opposed to same time last year (77% vs.)72%). The increase can be attributed due the payment going towards Unregistered Provider increasing from 23%to 28%. A monthly breakdown can also seen Figure 14

FIGURE Figure: TOTAL PAYMENTS FOR THERAPY SUPPORT ITEMS BY PROVIDER REGISTRATION, 2021 – 2022

|Million| |–:–| |$Jan-21||Feb-21||Mar-21||Apr-21||May-21||Jun-21||Jul-21||Aug-21||Sep-21||Oct-21||Nov-21||Dec-21||Jan-22||Feb-22||Mar-22||Apr-22||May-22||June-22||July-22||August-22||September-22||October-22||November-22||December-22*
Source: NDIS internal administrative data. The top five types of therapists excluding Other Professionals claimed against within six months ending Dec.’, ‘22’ based on total payments were: Occupational Therapist ($****2,billion), Early Childhood professionals delivering Early childhood supports($*million) Behavioal Therapists ( $) million, Physiotherapists( $****** ) and Psychologists ($******) million. These five types accounted for $billion worth claims, comprising approximately 64%, close to two thirds the $** billion spent by NDIS therapy expenditure. It should be noted that prior 07/22, many type’s therapist was not categorized into individual support items but included in other Therapy Support. The breakdown these types of therapies captured after this date. Since July’, *22 it can reasonably assumed that many Supports delivered under

Disclosure Log

MR25/01967 FOI 24/25-2242

DISCLOSURE LOG

FIGURE 15: LARGEST TEN THERAPY TYPES BASED ON TOTAL PAYMENTS, OCTOBER 2020 – DECEMBER 2022

$ Million
Dec Qtr
Occupational Therapy
Note:
The above chart shows that occupational therapy (OT) was introduced as a standalone line from July 2022 and speech pathology followed in September/October.
Before these dates OT/Speech were claimed under other groups of therapies without clear indicators for support provided.
This section has shown the increase supply by providers delivering therapy supports to NDIS participants. However with growing number receiving such services this may put pressure on therapists needed continue supporting them.

Employment Statistics

On current reported data through Australian Health Practitioners Registration Agency(AHPRA), February 2023 Department’s Allied Health Factsheets Dashboard stated there are:•4179 Psychologists registered, up +26% between years •38582 Physiotherapists reg’d AHPRA year end; up+25%. From previous year •26904 OccupTherapists reg’d AHPRA year-end; up over last five yrs •5819 Podiatrists reg’d AHPRA year-end; up over past five yrs The total numbers have grown significantly in recent years, up about two-thirds since registration started at around nine thousand per profession. Those employed increased similarly.

Disclosure Log

Figure 16: Number Of Registered Therapists, 2017 To 2021

| | Occupational Therapists | Physiotherapists | Podiatrists | Psychologists | |-|-|-|-| | Number 50,000 & ⏴⏩& ⏺⏚B& ⏻⏚& ⏼⏫
|| || || | | Source: Department of Health and Aged Care Jobs and Skills Australia (formerly known as National Skills Commission) projects employment growth of the entire Australian workforce for five years to November 2026 at (9{.}1%). The growth in the therapy space will continue over this period with therapists making up three of the eleven fastest growing occupations, those being Audiologists and Speech Pathologists (34 {. } { .}%, close to four times the projected rate of growth of the entire Australian workforce over that period), Podiatrists (``31 {. }8 %```)and Physiotherapists ( ``28 {. }_7 %)as shownin Table [Table: Growth In Expenditure On Therapy By Funding Source] .GrowthInExpenditureOnTherapyByFundingSource,`[2016-17 To 2019-20]

Disclosure Log

Business Dynamism: Annual Pricing Review - 5.4

To supplement Scheme statistics, the National Disability Insurance Agency has analyzed registered provider payment activity. That means any payments made against agency-managed plans are considered paid directly from these providers.

Disclosure Log

Figure 18: Therapy Registered Provider Activity Movements, January 2021 – December 2022

New Activity as Percent of Total Half-Year Payments | Inactivity as Percent of Prior Total Half-Year Payments | — | | Source: NDIS Internal Administrative Data| Further analyses indicate that on average inactive registered providers received $4,234 in payments in the half-year prior to becoming inactive with 84% receiving less than $5,000; active providers averaged $107,199. The National Disability Insurance Agency conducted comparisons across comparable schemes using data up until March 31st and additional information from direct engagement. The agency has worked closely with sixteen Commonwealth State Schemes regarding therapy pricing compared against their limits. Main MBS items for allied health have a fee per hour slightly higher at $65.85/minute session equating an effective hourly rate above what is set under the NDIS system which charges lower rates but includes co-payments making scheduled fees more reflective overall costs.

Disclosure Log

2022–23 Annual Pricing Review

calculate the effective hourly price and are unable directly compare these prices so they do appear in Figure below. Overall NDIS prices most types therapies As illustrates current limits broadly consistent rates paid other schemes once proper account taken duration service co-payments provisions travel consumables However results indicate many types have been indexed over past year This appears put into middle lower range some offered Professionals such as Counsellors Occupational Therapists Rehabilitation Counselours Figure OTHER SCHEME PRICING COMPARED TO NDIS Source: Data from with NDIA internal calculations

Private Billing Rates

This section analyses data set private billing therapy services including weekday in-room services The dataset compiled by scanning provider websites Australia Prices for weekend initial telehealth consultations excluded Outliers removed also as well as some therapy services Teachers Personal training Osteopathy Therapy assistants Billing converted to based on length consultation Some sample observed were non-metropolitan areas Among top four therapists Physiotherapists (176%) Psychologists Clinical Psychologists Dietitians Art Music each accounted less than of there The study outliers where value hour rate was greater Quartile Interquartile or smaller Than quartile -Interquartile

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were at least 80 observations for each type of therapists besides Art Therapists (33). Figure shows that there are widely dispersed distributions among types of therapy services.

Distribution Of Private Billing Rates By Therapy Type

| State/Territory | Counseling | Art Therapy | Exercise Physiology | |- |- |-| | Podiatry | Music Therapy || | Social Worker | Speech Pathology | Occupational Therapy | | Dietetics | Physiotherapy | Audiology | | Psychology - Clinical | Psychology | Figure: The geographic spread indicates Victoria has a higher proportion, followed closely by Queensland with New South Wales being underrepresented compared to others.

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Figure 21: Distribution Of Private Billing Rates By State

Table 9 displays summary distributional statistics of the sample of private billing rates. The average effective hourly rate for weekday in-room therapists in the sample was $184 (median $185). The smallest effective hourly rate that was observed in the data set was $73 and the largest was $360. TABLE: Summary Statistics OF PRIVATE BILLING RATE SAMPLE BY THERAPY TYPE | Type of Therapy | Count | Mean | Standard Deviation | Minimum | 25th percentile | Median | 75th Percentile | Maximum | |- |- |- |- |- |- |- |-| | Art Therapists | redacted | $140.2 | - | $73.3 | <$100> | $135.0 | $177.5 | $216.0 | Audiologists | redacted | $194.6 | - | $156.7 | $175.0 | $187.5 | $210.0 | $240.0 | Counsellors | 186 | $138.8 | '36' | ‘$75.0’ | ‘<$120>’ | $140.0 | $160.0 | $220.0 | Dietitians | ’ redacted’ | $174.9 | ’-|$80.0|$140.|$180. | $210. | `$280.0`` | Exercise Physiologists |

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2022–23 Annual Pricing Review

The test found that Audiologists, Dietitians, Music Therapists, Occupational Therapists, Physiotherapists, Podiatrists, Social Workers, Speech Pathologists (group 1 – base case), had similar means; while Counsellors, Exercise Physiologists and Art Therapists(group 2); also have similar means. Modeling began with indicator variables each state/territory(model 1), plus a regional indicator variable model(2)and including aforementioned groups therapies(model). Model4 included all states regions individual therapy types individually New South Wales as baseline sensitivity testing run various interaction terms between States Territories region indicators were investigated many which insignificant. table: Statistical Models Private Billing Rates| Variable | Constant | Victoria | Queensland | South Australia | Western Australia | Northern Territory | Australian Capital Territory | Tasmania | |- |- |- |- |- |- |- |-| |Constant | 193.**** | -6. *** | -20.*** | -*.3 .| .3 . | -.6 .|..8 .|| Victoria |-.1. ||*-12 .**** |-*8 .**** |=*-11 .**** \ Queensland | *=–20 .**** |=−20 .*** |==∗ −19 .|== ∗ =−18 .** \SouthAustralia |=-3 ..|=−9..``|=−10…|`=−12 ... WesternAustralia |=.3 |`=−3....|=−7 ....``|=−7…..NorthernTerritory |-= 6......|`=−0.......|=−6........``|=+9………AustralianCapitalTerritory |==+.2 ```|`= +2 .....|=−7 ......``|=−6 ……..Tasmania |+=8..........|`= +=12 ..........|= ++19………``|=++13 …….``Regional N/A |=−19.5****|=−11.9*****|=−12,5**ExercisePhysiologistsCounsellorsArtTherapistsN/AN/AArt TherapistsClinicalPsychologistsnAAdjusted R²F StatisticObservations ()p< .05,** p < , *** p< Model is preferred to Model as the small increase in R-squared between and does not adequately compensate for many variables being insignificant at level.

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2022-23 Annual Pricing Review

The explanatory power of model is only 37%, which suggests there that many other factors affecting therapy pricing than those captured in current models. Results suggest an average hourly rate $$189 per hour, with most therapists across New South Wales being lower priced compared others states/territories; hence suggesting adequate NDIS prices are still appropriate for majority practitioners. Results also show non-clinical Psychologists/Counsellors/Exercise Physiologists’ rates aligning well within these guidelines as well.

Consultation feedback (Section: Section)

The topic regarding therapy supports received significant public consultation input - out of a total submissions of 304, over half (57%) documented concerns or comments on this matter. Many providers highlighted increasing supply costs and wages as primary cost drivers while additional expenses included staff attraction/training retention & quality/safeguarding compliance issues were noted too. Several participants indicated they charged more to NDIS clients but generally supported no further price increases at present timepoint. See Appendix A detailing common themes raised from consultations related to APR Paper.

Recommendations:

on balance available data indicates the adequacy of existing NDIS limits for therapy services based upon comparable government insurance/funding schemes/private market billing rates supporting such findings. Recommendations consider growing demand among NDIS users claiming therapies met by provider growth reflecting 17% user claims vs only 14% in service provision. Recent years have seen increased numbers of Therapy Professionals which is expected to continue, helping alleviate potential workforce shortages where needed regions exist. it’s evident that diverse needs across vast therapy markets necessitate structural changes post relevant NDIA recommendations following current non-price focused reviews.

  • Recommendation #6 The NDIA should not make any adjustments to pricing arrangements nor index prices effective July ’23.
  • Recommendation #7 Consideration required regarding structure of therapy support pricing after relevant NDIS Review conclusions aimed towards enhancing service quality delivery and fostering greater efficiency within these frameworks.

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Section 6 - Support Coordination

Subsection 6.1 Context

Context: Support coordination is capacity-building support provided through NDIS funds that helps individuals maximize use out of individualized plans while pursuing goals. It involves connecting clients via brokered mainstream or NDIS-funded services in line with client wishes and budget constraints; building skills related directly towards understanding one’s own plan, navigating NDIS processes independently; supervising spending within budgets as well ensuring effectiveness thereof. The role also entails identifying available service options locally, making connections between participants & providers who meet needs/preferences for continuity of care/services where possible. In addition they must be able to link participants into community-based informal resources when appropriate. They should demonstrate initiative and innovation whilst helping clients align their preferences/budgets accordingly. All these activities need adherence strictly following NDIS Code Conduct which mandates provision under safe competent conditions w/care skillful execution without registration requirement unless delivering specific types of supports listed below:

  • Registration Group: Assistance Coordinating Life Stages Transitions Supports -> Core Module Practice Standards Compliance required. This includes participant rights provider responsibilities governance management standards etc., along with the way such assistance shall be delivered. Registration Group Specialised Support Coordination requires further compliance per Module4 Practice Standard covering additional provisions regarding conflict-of-interest handling among others. NDIA has developed pricing framework considering varying levels support coordination needed by each participant ranging from basic connection up till high-level specialist level. This aims at providing fair sustainable funding model enabling recipients receive necessary aid leading fulfilling lives. Currently coordinators can claim four distinct services categories including but not limited too:
  • Level 1: Helps implement plans through strengthening ability connecting broader systems understanding purpose funded supports.

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  • Level 2: Coordination of Supports strengthens a participant’s ability to design and then build their supports with emphasis linking broader systems support across complex service delivery environment.
  • Level 3: Specialist Support Coordination utilises expert or specialist approach necessitated specific high-complex needs in participants’ situation.
  • Capacity Building Training Self-Management Plan Management assists building capacity administer manage plan The price limits these supports set out Table below: table| Item Number | Item Name Notes | Unit | Non Remote | Remote | Very Remote | |-|-|-|-|-|-| | Item | Number | Name & Notes | Unit | NonRemote | Remote | VeryRemote | | 7_001 _ _016_8_3 | Support Coordination Level : Support Connection | Hour | $70 .94 | $59 .22 | $63 .31 | | 7_002 _ _016_8_3 | Support Coordination Level : Coordinationsupports | Hour | $10.14 | $14 0,19 | $15 ,21 | | 7_004 _ _0132_8_3 | Support Coordination Level : Specialsupport coordination | Hour | $190 ;$54 | $266 .$75 | $285.$80 | | 134_0117_8_1 | Capacity Building Training SelfManagement Plan Management | Hour | $70 .87 | $99 .22 | $106$.31 |

Support coordinators permitted subject rules set out NDIS Pricing Arrangements Price Limits claim provider travel labour non-labour costs; non-face-to-face activities NDIA requested reports short notice cancellations. The chapter analyses pricing arrangements for support coordination focus effectiveness promoting innovation enhancing service quality ensuring value money examines current price arrangement usage statistics providers markets stakeholder concerns draws conclusions potential changes to the framework objective provide comprehensive understanding of this framework impact on participants title: Scheme Statistics Some unique providers delivered support coordination supports (including capacity building and training) participant six months December active participants This equated payments amounting million in payments total scheme spend increase compared six month December Table below displays change some these statistics June 2021 DecembertoDecember 2022: table| Statistic | July – December, ,2021 | July -Decembe r-–2022 | Percentage Change| |-|-|-| | Total number ndis participants | 182,938 | 210,*,0***9** | +5%

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| Statistics | July – December \n\t \t   2021 | July -December\ nbsp;      2022 | Percentage Change | |-:|–:-||–::––::-:—–:——:—––| | Total number of active providers |5, 

Footnotes[fn_4].
<footer class=“meta-date” datetime=“2023-03-15T14:28:09Z” itemprop=“datePublished” itemtype=“http://schema.org/Dates> Published:<a href=/blog/what-is-a-corporate-sustainability-report/>March 15, 2023</a>. Last updated on March 15,

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Annual Pricing Review

Distribution Of Participants And Providers Claiming Support Coordination Supports,

Figure 23 - December 2020 To December 2022

The figure shows that there is potential for a single provider to appear across multiple categories as they can deliver different levels of support coordination within one time frame. The split between Level 2 and other levels continues its rapid pace with more than double participation since Dec ’20 compared to Dec’22.

Business Dynamism

To supplement the Scheme statistics, the NDIA has analysed registered provider payment activity. That is, payments made against Agency and Plan Managed plans are considered to be made by registered providers.

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Figure 26: Registered Support Coordination Provider Half-Yearly Payments Histogram (June 2020 – December 2022)

To further assess the current state of the provider market, payment activities of registered providers across a two-year period from January 2021 to December 2022 were analyzed. Payers with New Activity during any given six-month span include those without prior payments; Inactivity is defined as having no recent activity but previous payments exist. Each payer’s contribution reflects their share out of all payments within each respective time frame or preceding one if it pertains specifically toward new activity versus past periods regarding inactiveness.The NDIA acknowledges this isn’t an ideal measure for tracking exits yet offers what can be considered closest approximation based upon available data. The findings indicate over these last couple years, inactive support coordination payers contributed less than just under one percent towards total expenditures annually while active ones accounted between approximately 1% and roughly 3%, respectively. Moreover, inactive registrants typically served around seven participants per half year leading up until they ceased operations; halfway through that timeframe though only about sixty percent had been servicing merely single clients whereas another eight percent managed more than twenty individuals before ceasing service altogether. Conversely,in the same twelve months ending at Dec ’22,fourteen percentof currently operational entities catered solely to solitary customers compared against forty-five percent who handled greater numbers exceeding even twenties which collectively represent nearly ninety-seven percent overall spending directed by registered support coordinators throughout said period.

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FIGURE 27: SUPPORT COORDINATION REGISTERED PROVIDER ACTIVITY MOVEMENTS, JANUARY 2021 – DECEMBER 2022

New Activity as Percent of Total Half-Year Payments Inactivity as Percent of Prior Total Half-Year Payments

Source: NDIS Internal Administrative Data

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Recommendations (2022-23 Annual Pricing Review)

DIA’s submission suggested that providers delivering support coordination appear to be considerably less than NDIA reported numbers, suggesting two different registration groups may conflate these figures. They also commented that the relative growth of support coordination providers is overall less than that of other types of supports delivered in the NDIS. Another point raised was that perceived growth of providers may capture the potential situation where, for example, one provider of support coordination exits NDIS services but there are entrants of new smaller providers claiming for support coordination from staff exited providers. DIA suggested an estimate of approximately 80% ‘new providers’ entering the market as employees of exited providers.‘’ DIA also raised concerns on unfunded work undertaken by support coordinators along with bereavement costs associated with support coordinators providing care after a participant’s death. The NDIA considers ongoing growth occurring within supply provided through registered/unregistered providers; however, this has been driven primarily via unregistered providers serving participants at roughly equal rates between both categories.` Further themes echoed included greater clarity needed regarding roles and responsibilities assigned under the NDIS alongside fragmented funding arrangements impacting service delivery quality. NDIS review currently underway considering intermediary role recommendations 30 & 33 from previous year (21-22). As such, the NDIA should consider structural changes to pricing arrangement post-review completion. on balance, no increase required price limits Level Coordination Supports Services or Specialist Support Coordination Services due increased provider numbers delivering these services to NDIS participants.“ Therefore recommended not changing prices July except Level:Support Connection item set per NDIS Cost Model alignment continues.

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  • Index price limits Level: Support Connection services July 1st 2023 in line indexation supports determined NDIS Disability Worker Cost Model recommendation.
  • Not indexing prices Limits Coordination Supports Services Specialist Support Coordination Services July 1th 2023. The National Disability Insurance Agency (NDIA) sees merit benchmark survey conducted DIA better capture specific cost drivers faced coordination providers This also considers respondents reported employees SCHADS Award makes it reasonable justify having Cost Models Levels: Recommendation: After outcomes announced, NDIA sector appropriate stakeholders develop Cost Models for levels: supports and level specialist support coordination The NDIA also instances where coordinators undertake work following participants’ deaths administrative associated gathering information returning equipment completing forms In addition significant changes situations such interactions justice health may require additional administrative responding subpoenas critical details required As such should examine options allow coordinators claim payments Recommendation: Should examine billable work required after participant’s death or other key events.

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Chapter 7 - Plan management supports

Section 7.1 Context

Context: Plan managers play a crucial role in NDIS ensuring sustainable systems while assisting participants manage funding through plans. The chapter examines how these arrangements promote innovation, enhance quality services; support value money for participants. Funding provided within participant’s plan can be managed wholly or partly: bystatus;registered plan manager (“plan manager”); orby NDIA; oorby appointed plan nominee if one exists). currently,participants choose (subject terms any appointment) engage registered plan manager managing some all funds support their plan.If this choice made then current requirement give effect participant’s choice.NDIA also include fundingparticipant’s so they can prefer registered plan manager. NDIS Act requires plan managers to register with NDIS Quality and Safeguards Commission (NDIS Commission). As result must demonstrate compliance Core Module of Practice Standards comply Code Conduct have complaints resolution system record manage complainssuppose NDIS participants other relevant parties make complainthave incident management notify commission reportable occur including alleged incidents fulfil worker screening requirements where applicable. Also bound by Pricing Arrangements Price Limits.Plan-managed participants only purchase listed Supports Catalogue subject same billing rules price limits agency-managed but can from registered/unregistered providers except determined NDIS Commission particular type support. Managers receive disburse on behalf participant provide other service received participant assist directly funds in the participant’s plan pay provider help keep track fund taking care financial reporting participants.In cases, also help select providers. Must ABN deliver support payment requests unless exempt quoting ATO rules. Exempt complete Statement Supplier form Plan managers expected copy completed ensure valid tax invoice included each request includes

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relevant information about the goods and/or services purchased. Plan managers may be liable to pay back any amount not spent in accordance with participant’s plan.

Plan Managers can claim three types:

  • A one-off per-plan establishment fee: setting up financial management arrangements;
  • Monthly fees; ongoing maintenance arrangement support capacity building training, in self-management and plan administration. The price limits are set out below.

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TABLE 14: PLAN MANAGEMENT SCHEME STATISTICS

| Statistics | July – December \n\t \t 2021 | July -December\ null * 2022* | Percentage Change | |-|-|-| | Total number of NDIS participants | $365 million | $7 billion | +$2% | | Total number of active providers | 1 ,588 | 1 .797 | +%1% +13%% | | Total plan management fees claimed | $20 milliion | $22billion | +%14% |$228million | +14% |||| Total number of active providers claiming fees | 1,185 | 1,318 | +%11% Average amount claimed fees per provider | $168milion | $172,milinon | +%1% Source : NDIS administrative data Note figures above are based on payments made for relevant plan managemen supports Therefore the figuress may differ from actual number of plan managers registered with NDIS Commission to deliver plan management suppor The total number oNDS active particpants who are partly or fully plan managed my differto numberofparticpants that usedplanmanagement services inthe time periods presentedabove.

Participants Over half all participents usd a plan manager (58%) during December quarter and nearly halfofpaymentsmadefromNDISpland budgets were claim bya plam manaer(4%). These have increased from %&&

Figure below illustrates share participants planmanaged Figure showsshare payment processed by plan mangersincreased significantly last two years.\n**FIGURE DISTRIBUTION OF PARTICIPANTS BY METHOD PLAN MANAGEMENT OCTOBER DECEMBER \t 2022* Per Cent Dec Qtr MarQr Jun Qt SepQt Dec Qt May Qt June Qt Sept Qt Dec Qt <div>

Agency-managed Self-Managed Plan- ted 32% 47% 69% 51% 53% 54% 56% 57% 58% Source: NIDS internal administrative data

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Providers

During the period December 2020 to December 2022, the number of plan managers increased from 1,098redacted: s22(1)(a)(ii) - irrelevant material in the six months to December 2020 to *1,797redacted: s22(1)(a)(ii) - irrelevant material in the six months to December 2022, an average six-month increase of 14%. Aside from most recent six months, there has been growth in providers of plan management supports. See Figure 30 for the trend over this period. Data suggests a slight reduction in the number of plan managers int he six monthsto Decembe r2022 andthe NDIA will continueto monitorth e healthof th ep lan managem ent market. Overthes ame time,the num ber o f participants partly or fullyplan-managedincreasedfrom\n \n189 ,229 redacted: s22 ( )-irrelevant tot otal 333.077 – anaverage sixmonthincrease of ***5%. This indicates that while newplannmanagers are entering them arketand increasing participant choice, many pl annan mangersare also expanding as theratio oft particip ants top rovidershas increased.Theparticipanttoprovider ratioint h esixmonths t odecem be r2022 is 1,*85participants per providero f p lana nagementsupports.redacted: s22(1)(a) - irrelevant material

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Market health indicators

To understand the current health of the plan manager market within the above context, NDIS payment data of the top five plan managers were also analysed.

The top five plan managers processed 2 million transactions during July and December 2 period including two millions for plan management fee. In six months Decembe 2022 ,average amount claim provider per participant was $126734 . The largest five plan managers received $ billion more than quarter ( )of$ billion of plan managed payments inclusive of fees These top five plan managers have dominated over past nine quarters having consistently stayed ten with payments process Figure 31 ”” Scheme expenditure Largest Five Plan Managers Based on Total Payments October DECEMBER Source: NDIS internal administrative data Participant providers plans support ratios have seen larger number participants average being covered by Provider of plan management supports As numbers increased relative to provider numbers The average number servicing between December quarter and December quarter This ratio has largely due overall growth provider numbers by %being offset by Growth in participant numbers However,in six month December the number claiming decreased by which contrasts previous%growth seen six months December NDIA should continue monitor movement Providers claiming future quarters determine trend Further,the average funds management ratio total costs monthly plan management FY where average management ratio purchasedwas%.This means cost claimed proportionally to cost through managements may be range reasons such as

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Business Dynamism

To supplement Scheme statistics, the National Disability Insurance Agency has analyzed registered provider payment activities. That means any payments made against agency-managed plans are considered paid directly from NDIS funds managed through those agencies, as well as all other types like plan management supports provided under these arrangements: Figure below shows how many providers received at least one payment during June/July ’20 - December’22 split into six-month periods. The chart indicates most providers were active throughout their entire time frame (35%), counting up almost entirely toward overall spending ($95%). Further analysis looked specifically within January-December 21-”„22 timeframe on whether each provider was newly active or inactive compared to prior periods; inactive providers accounted barely anything while new ones represented a small but significant portion.

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Figure 33: Plan Manager Activity Movements (January 2021 – December 2022)

Further results indicate that on average inactive registered plan managers claimed for $32,526 payments during their last active period before becoming inactive; this is compared against an amount less than $5,000 from those providers claiming within six months prior. The opposite trend was observed among actively managing plans where these individuals averaged claims over three times higher at approximately $3,839,694 per half-yearly cycle, highlighting lesser amounts being claimed overall relative new and existing registered providers.

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Recommendations (MR25/01967 FOI 24/25-2242)

Annual Pricing Review: 2022–23

The available information indicates that the market supporting plans’ financial outcomes has been relatively healthy. Besides December’s quarter, there were strong growths over previous nine quarters due to increasing demand from participants managed through providers with plan-managed services being acknowledged as an increase per provider servicing more individuals who are both fully and partly plan-managed according to feedback received during public consultations in line with recommendations made previously within APR reports between years ending March ’21-’22 which suggested clearer guidelines regarding roles played out by plan managers. The National Disability Insurance Agency believes insufficient evidence exists currently indicating a need or justification towards making structural adjustments impacting NDIS pricing arrangements related specifically toward managing costs associated directly linked back into technological transitions tied closely alongside new PACE systems introduced recently along side heightened cybersecurity requirements placed upon those responsible for overseeing these matters. In light thereof, a recommendation is hereby proposed: Recommendation: The NDIA should not make any structural adjustment concerning changes affecting NDIS pricing structures pertaining particularly around management fees relating exclusively focused on providing support via plan managements until further clarification of expectations surrounding said role can be achieved.

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NDIS Pricing

The National Disability Insurance Agency (NDIA) acknowledges this Annual Pricing Review has a targeted scope of supports as outlined in the Terms of Reference. Some recommendations within this chapter are outside the scope but form part of overarching pricing considerations for NDIA, suggesting improvements could be made future processes more transparently:

Non-SCHADS Labour Supports, particularly Nursing support is considered critical without specific review during APR cycle; it’s essential that real value maintained on price limits to ensure supply remains stable and quality improved through innovation. The NDIA recognizes there’s range not covered under current APR or linked with DSW Cost Model, nor benchmarked against SCHADS Award; these aren’t subject to price limitations either. Nursing services fall into such category alongside core capacity-building areas like personal domestic cleaning etc., requiring similar measures ensuring they remain competitive compared other markets due aging reforms including wage increases up-to-date by aged care workers’ pay rise. Without increasing prices it may pose risks participants receiving nursing support. Therefore necessary increase must align previous year indexation methodology. Recommendation 12 is proposed: The NDIA should consider any recommendation arising from annual reviews and future ones. Increase non-DSW-related supports’ price limit effective July 01st 23 based weighted movements over last twelve months in ABS Wage Price Index (Australia excluding bonuses) & Consumer Price Index (All Groups weighted average across eight capital cities) to March Quarter immediately preceding the indexing date (80/20 weighting).

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Section: 8.2 NDIS Cancellation Policy

The text from your source page has been preserved as closely and accurately as possible without paraphrasing or rewording.

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acknowledges this may impact some supports and outcomes under the scope of the APR, which should be considered in line with upcoming recommendations from the NDIS Review expected in October 2023.

Recommendation 14

The NDIA should continue to work with the NDIS Review on relevant topics and issues involving structural changes to the current NDIS pricing arrangements.

Section: NDIS Pricing Strategy Refresh

The pricing arrangements for the NDIS are governed by the NDIS Pricing Strategy30, which was adopted by the NDIA Board in 2019. The Strategy recognises that in the short-to-medium term the NDIS’s pricing arrangements must consider both the need for value-for-money (and hence efficiency) provider operations, as well as ensuring continued access to supports including rapidly expanding supply during roll-out.
During rollout of the NDIS market disability support needed develop at pace with significant increases production efficiency improvements quality
 While improvement production efficiency will reduce costs long run expansion market supply necessitates higher prices especially where case NDIS supply maintained ensure participants receive critical
The *NDIS Pricing Strategy recognized high short-term price limits would maintain expand provision disabilities supports providing incentive redirection resources economy.

<div class=

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how it is functioning. A market that is considered well-functioning requires less intervention.Therefore, the NDIA ­should examine what might be the most appropriate measures to apply across different markets delivering NDIS supports based on the current market maturity,economic conditions as well as Scheme trajectory. Recommendation_15 The \NDIA should refreshitsNDSIPricingStrategy toreensureitssappropriatenessonthecurrent stateofNSISsupportmarkets,inconsiderationtotheoutcomesfromthenDSDReview.

Financial ReportingbyNDISPvidersThe NDIA believesitis imperativethatasamarket steward,itis importanttomonitorand tracktheadfinancialperformanceofproviderswithinthesector to ensuretha theyremain financially viable.As noted in section3.12 previous attempts toc conduct surveys togauge providers financial bottomline has resultedinpoor response rates and therefore theresultsare not considertoberepresentative ofentire provider sector.The NDIA doesnot consider thatitinecessarytocconduct a finanbenchmarkingsurveyi ngiven thecurrent APRhasatailored scope.Moreover,the

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Disclosure Log: 2022–23 Annual Pricing Review - Recommendation 16

The NDIA should explore options with the NDIS Review regarding possible mandatory financial reporting requirements imposed upon NDIS service suppliers concerning specific economic indicators, aimed at supporting and enhancing the NDIA’s oversight responsibilities.

Appendix A – Feedback from the Consultation Paper

Overview

A consultation paper on annual pricing review (APR) feedback received.

  • Consultation release date: March 17th, 2023,
  • Submission closing time & date:* Thursday April 13rd at midnight Australian Eastern Standard Time with total submissions counted as 304** Most were submitted:
  • Provider organizations (165) – Employees/Workers ( extbf{96}) Small number came directly through participants’ representatives (12). Also included:
  • Professional bodies (15
  • Peak provider bodies (9
  • Government entities (3)
  • Advocacy groups (3) – Workers unions (`1)

Labour Market

Of all responses(304), a significant portion related specifically towards labour market issues (76). These concerns were raised across various sectors including providers and plan managers, employees/workers, professional associations, peak body representation along one submission each for advocacy group and government entity respectively.

Providers

It was widely recognized by these stakeholders that labor markets in both disability sector alongside broader economy have become increasingly tight over recent years. This observation has been echoed consistently throughout the consultations where employers reported difficulties attracting qualified staff due to rising living costs leading wages failing behind increasing expenses creating unsustainable conditions on behalf of workers and businesses alike. An exercise physiologist highlighted this issue stating,

The lack indexing fees against CPI erodes sustainability providing high level support NDIS patients more experienced professionals resulting less skilled service delivery. Providers also noted how highly-skilled personnel are leaving their positions elsewhere or within different industries because compensation packages do not align with current pricing structures. Multiple Sclerosis Australia stated, Staff turnover primarily driven higher paid opportunities competitive wage offers result substantial losses. one provider commented: The NDIS’s price arrangements limits did little assist hiring retaining workforce compared other industry private sectors. it is further observed mandatory requirements working sector complex difficult navigate which creates barriers moving between roles/organizations simplifying those demands ensuring skills training obtained setting transferable others suggested.

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One provider recommended:

Support work should be made into careers rather than jobs with pay reflecting them; simplify mandatory requirements so skills are transferable.

Provider Peak Bodies

Provider peak bodies shared similar sentiments about high workforce turnover in disability support sectors needing strategies like attracting workers long-term capabilities enhancement over years due to lack formal qualifications opting TAFE courses certification before entering but many leave roles after months establishing themselves independent practitioners according to Ability Roundtable data which states:

Many employees recruited trained within NDIS leaving particularly under age those less three years supported National Disability Services advising labour shortages wage growth directly influence providers bottom line Aged Care Award increase making it more difficult attract DSW workers.

Professional Bodies

Professional bodies echoed shortage skilled labor sector as qualified can command higher rates independently lower overhead costs several submissions proposed addressing this through investing efforts recruiting students interested allied health practical experience integrated curricula demonstrate viability industry hoping better equipped make informed decisions future career pathways nurturing pipeline talent well versed specific needs challenges faced by the industry.

Registration Costs

There were sixty-six submissions regarding registration including quality and safeguarding from various supports plan managers, employee/workers professional bodies peer groups advocacy group numerous providers indicated that process is perceived both time-consuming costly irrespective business size administrative burden resources dedicated monitor compliance onboard new staff implement complex administration

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systems, which detracts from their core business activities. Several submissions highlight the need for businesses to hire additional staff to manage compliance registration requirements, apose simpler streamlined registration compliances processes. The Spinal Cord Injuries Australia submitted:

Administrative tasks associated registration managing Clinical Governance Committee complex consuming costly high costs registration currently reflected pricing structure NDLS create long term sustainability challenges.Another provider noted Generally administrative/registration tasks have increased last year worker participant numbers largely remained stable during this period; compliance tasks increase.A common theme seen numerous submissions confusion caused changes NDIS price guide due SCHADS award One submission said:* Complexity interrelationship cost any business trying navigate compliant approach multiple agencies.Although stakeholders raised concerns lengthy nature administration registration process some noted motivated them enhance service standards regulatory requirement each provider formally review semi regular basis Overall positive sentiment expressed these processes provided participants providers assurance complying relevant standards regulations despite associated costs one provider stated:*It is beneficial our organisation registered NDIS provider Registration ensures compliance safeguarding participants Audits something welcome sector but come as an additional burden registered providers.### Professional bodiesMany peak body observed benefits being a registered provider decreasing decline agency managed participants Associated time uncertainty future of agency-managed participants pose significant challenge providers Additionally perceived themselves disadvantage competing unregistered providers not burdened same costs and constraints creates uneven playing field market which can lead further challenges for registered providers.The Speech Pathology Australia (SPA) submission states that:**The process registering to be out reach many financial terms fulfilling all requirements.


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Disclosure Log: Annual Pricing Review for 2022–23

Some participants receiving less funding than they require due to reduced quality care. Many providers felt DSW Cost Model insufficient as it doesn’t cover legislative compliance requirements or IT infrastructure investment. The simplified model covers workers’ compensation but lacks visibility into broader cost categories like annual leave allowances which don’t accommodate five-week shift worker allowance; long service leaves vary between states with differing public holidays; split shifts add considerable payroll burden making rostering challenging, as one provider mentioned:

The split shift allowance has added a considerable amount to the payroll… With extra administration time plus additional costs smaller shifts are becoming harder viable. Several providers feel SCHADS Award changes along with increased cost-of-living pressures have led more staff working casually because take-home pay is higher, including declining on public holiday shifts where employers must compensate two staff members if original fails in sickness. Workforce recruitment and retention alongside training development were recurring themes indicating that current models do not account adequately these activities’ expenses. Preliminary findings from Ability Roundtable’s financial benchmark survey conducted among twenty-four DSW organizations reveal an average operating loss of $81 million (or approximately three percent) across respondents despite their collective revenue exceeding over$7 billion in total sales during this period while estimating 15% impact by SCHADS award adjustments per year.

Disclosure Log

MR25/01967 FOI 24/25-2242 Annual Pricing Review (2022–23)

NDIS DSW Cost Model has significant consequences for training development sector capacity.

The NDIS DSW cost model has had significant consequences for training & development within this field and reduced participation from service providers providing high standards through supervision. There were cutbacks allocated time for training team meetings disappeared, severe curtailment supervisions occurred with large numbers casual workers being newly employed without adequate oversight at all times. Increased competition – mobility contributed difficulty attracting skilled staff under SCHADS award intensified in thin markets rural regional areas.

Participants:

Several participants or their representatives felt wide variance skills among support workers despite same pay rates. Concerns over a seven-day cancellation rule affecting some providers alike when appointments are cancelled there is additional costs provider overtime casual loadings as one participant said: lost good worker because hospital kept altering my appointment which messed her own timetable until she was essentially forced to seek other more reliable work.

Impact of COVID:

COVID continued past year creating challenges many providers including increased absenteeism agency staff required backfill shifts sick leave exhausted exacerbated by supported independent living specialized disability accommodation services. Some providers mentioned ongoing costs related staff training infection control methods maintaining PPE stockpiles difficult account under the DSW cost model further cancellations due to COVID reported increasing others absorbed into current business arrangements Australian Psychosocial Alliance stated overall members reported reduction associated costs six months however overhead burden planning responses across entire businesses remains significant.

Impact Aged Care Award increases

Providers feel that increase aged care awards will not directly impact on workforce demands and costs. One provider both aged care & disability service stated, “We do not anticipate any marked shift from disability support staff wanting exit Aged Care.”

Disclosure Log

Therapy Supports

There were 173 submissions related to Therapy supports. These were received from all stakeholder groups including, promoters and suppliers for both therapies as well as other forms support, supervisors or managers along with workers/employees involved directly within these services; customers themselves either individually or through their representatives; group leaders representing various organizations such as professional bodies, an advocacy group specifically focused around disability rights issues in Australia together with government agencies responsible for overseeing this sector.

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Figure 34: Deloitte Access Economics Estimated Cost Per Hour Of Allied Health Services Under THE NDIsu, 2021 (Left Hand Side) Compared To 2022 (Right Hand Side)

| | Left Hand Side - $200.34 | Right Hand Side - $207.81 | |-|-| |Base Pay|$$^{*}$|| |Non-service level staff cost|$^{}$$|^{|}|$ |Service related oncots|$^{}$$|^{|}^^{+}\textcolor[rgb]{ .7 , . ] { } {$^{}$$|^{|}}^ h e r p t i s m o d u l e ^ {} $$|^ {|} a n c y a n c y $ |Training and PD|$^{}$$|^{|}^^{+}\textcolor[rgb]{ . ] {. } a n c y$r a n c y$ |Other salary oncosts|$^{}$$|^{|}^^{+}\textcolor[rgb]{ . ]. } a n c y$r a n c y$ |Utilisation|$^{}$$|^{|}^^{+}\textcolor[rgb]{ }. } a n c y$r a n c y$ |Corporate overheads|$^{}$$|^{|}^^{+}\textcolor[rgb]{ }. } a n c y$r a n c y$

Notes: Four major allied health disciplines (excluding psychology) are the weighted average of social worker, speech pathologist, occupational therapist and physiotherapist. *2022-23 price limits are calculated based on location and discipline within organisations using NDIS Pricing Arrangements.

The key findings from Deloitte Access Economics Report include:

  • At an overall level in 2022 for four major allied health disciplines excluding psychology), costs increased by approximately 3%; while Psychology saw growth at around 4%.*
  • Labour-related cost increases were noted as follows - 15% increase across all four main groups, with *a further rise to about double that amount observed specifically among psychologists due primarily to wage rises and salary related expenses along with investment into recruitment training new staff.
  • Overhead costs rose significantly throughout these sectors reaching up nearly one-fifth higher than previous years mainly driven IT expenditure HR spending quality compliance requirements*
  • Despite this pressure providers managed savings through improved efficiency better use resources reduced non-labour expenditures such as supervision back office restructuring etc..* Most surveyed organizations report struggling financially operating above current NDIsu prices limit therapy supports during year ending March 2022 . A peak body early childhood intervention stated unfunded activities not billable included child protection referrals involvement subpoenas family law court proceedings mandatory reporting obligations .* Based small survey conducted National Disability Services (NDS) reveals significant gaps between actual service delivery costs versus those set under the NDI system. According State Sector (2022) based Annual Market Survey indicates past twelve months challenging period faced many operators.

— Page:836 of total pages :97 –

Disclosure Log

Professional bodies

Several professional bodies reported pricing arrangements for therapeutic supports under the NDIS are not reflective of true costs for providers especially when considering inflation, workforce shortages, impact of COVID and NDIS client complexity. The costs felt acutely in rural areas because factors such competition around wages housing shortage increased cost travel consumables. Many professional bodies suggested increase NDLS therapy support payments may be result increasing provider numbers participant having knowledge choice control over how they invest their funds.NDLS providers often provide unpaid or underpaid labour subsidise plan which can impact business higher costs. Allied Health Professions Australia (AHPA) who represents some allied health professionals stated data recently gathered from more than speech pathologists showed that less quarter report charging rate participants majority all clients same fee Some physiotherapists particularly report charge non-NDIS clients a higher as reflects service The reasons given include complex level skill involved experience additional supervision development requirements Their submission states Therapy providers overwhelmingly de-registering choosing see self-managed managed due burden Of those registered just indicated were intending register This concurred another peak body Speech Pathology Australia also stated differentiated prices frequently referred discount people families unable access funding therefore reach Australian Association Psychologists Incorporated performed survey November 2022 results indicating significant demand services disability sector psychologists recommended fees considerably higher price caps suggesting psychology funded levels low education training associated registration practice psychologist.Australian New Zealand Asian Creative Arts Therapies Association ANZACATA professional on creative arts therapies said group Art Therapy NDIS not viable use materials time spent writing case notes expertise required facilitate keep safe episodic nature psycho-social disability its impact provision poses challenge irregular attendance patterns hard to regular work conditions contracts attract staff

Participants

DISCLOSURE LOG

MR25/01967 FOI 24/25-2242 Annual Pricing Review (2022–23)

More than half of those who responded stated they pay more per hour compared to non-”NDIS clients. A participant receiving supports from both Disability Support Workers & Therapists said:

However regarding therapy services once you inform a provider that your client is an NDIS client then regardless which provider I ask about cost per hour it will be charged at maximum price under NDIS system. Meanwhile members without being ”NDIS clients” but receive same length time service for Physiotherapist or Exercise Physiologist get less charge as myself. The other self-managed person now plan managed has double hourly rate in podiatry physiotherapy sessions. a respondent suggested not increase max amount Occupational Therapy can charge because he believes OTs overcharge currently another response follows: The participants are forced higher prices due providers tend charging max limit Regrettably this happens when demand exceeds supply so no competition among providers and no incentive to charge them below the NDIA pricing arrangements limits stipulated amounts.### Advocacy groupsAn advocacy group states current pricing inconsistent with true costs hiring allied health professionals Providers may face increased after-hours staffing travel expenses rural remote locations covered by NDIS coupled administrative requirements leading greater workload on providers#### Support coordination99 submissions addressed support coordination made by participants, providers managers employees/workers peak bodies advocate group##### ProvidersProviders raised lack of price increases level 3 combined SCHADS Award increases reduced margins prompting financial sustainability concerns Cost factors such Workcover registration audits portable long leave COVID related superannuation utilities rent impacting support coordination’s sustainability amongst providers In addition Pricing model does not adequately consider fragmented nature unbillable hours spent phone calls emails invoicing filing


2022-23 Annual Pricing Review impacting providers, with an average of 20 hours of unpaid work per week. One provider suggested: to work on average 20 hours of paid work per week, such as phone calls, emails, invoicing, filing etc., as part-time staff are not claimed but is a significant expense incurred (up to six out of twenty additional hours). Support coordinators often undertake unfunded tasks after their death includes administrative activities like gathering information from insurance companies or completing forms for equipment return.

DISCLOSURE LOG

MR25/01967 FOI 24/25-2242 Annual Pricing Review (2022–23)

The fact that we receive fees from NDIS for providing plan management services has remained unchanged over recent years; however, rising costs associated with these services result in a real reduction each year available funds dedicated directly towards service delivery. Some providers detailed tasks performed daily within their roles as plan managers along challenges posed due heightened demand across various areas:

  • Briefing clients/carers/support coordinators regarding understanding & application of NDIS price guidelines;
  • Managing complex claims involving diverse physical or mental health needs requiring more significant effort than standard cases, Spinal Cord Injuries Australia highlighted: The current pricing structure fails adequately cover time needed managing intricate client situations leading higher staffing levels. Plan Managers are responsible implementing plans processing invoices preparing budget reports assisting gathering information planning meetings ensuring timely payments to service providers Increased invoice requests necessitate additional resources including frontline support staff technology employment. Like other provider types, attracting and retaining suitable personnel is increasingly difficult. Competition among providers impacts ability recruit qualified individuals. Maturing clientele often leads increased expectations on service quality High turnover rates were reported by several providers Australian Workers Union stating DSW industry characterized short-term tenure multiple employers paradoxically long term commitment contributing significantly high employee churn. The following statement was made about the role’s complexity: ‘Plan Management not easily found existing job market primarily clerical function requires 3-6 months acquiring sufficient knowledge applying NDIS Price Guide effectively.’ Respondents also addressed changes setup fees particularly concerning participant plans’ duration automatic extension arrangements Some noted workload per individual increases when setting up new plans completing renewals participants unaware review results causing delays in invoicing supports payment process slow some taking months processed.

Some plan managers felt their efforts creating larger plans especially those related Supported Independent Living Specialist Disability Accommodation recognized insufficiently Excessive invoicing for certain clients observed as well lack authority controlling ad hoc services requested only learning of these after receiving an invoice received, Providers mentioned IT software issues time resolving them along with heightened training demands systems/software verification requirements managing detecting potential fraud instances responding to

DISCLOSURE LOG

2022-23 Annual Pricing Review

customer conflicts of interest and responding to privacy related matters. In addition, is needed training in first aid mental health first aid understanding child safety indicators cultural awareness training NDIS processes pricing arrangements price limits framework Several plan management providers noted they would like clearer guidelines on role plans managers assist reducing administrative burden as well help understand fraud prevention More clearly defined roles may be scope review

Participants One participant previously self-managed stated fee group therapy doubled introduction manager They also felt lost independence running their own affairs Participant said:

My physiotherapist charged me $50 part hydrotherapy session I managed my NDIS plan Group included aged care injury recovery clients held sectioned off pool Now that has a plan manager just NDIS clients public side now costs Plan $100 This participant believed reviews should take place longer period make smoother more timely running NDIS plan: Plan Reviews could include meeting between participants family carers Local Area Co ordinator Occupational Therapist so comprehensive meets all needs person disability save time money meetings happen internet

Other commentary Providers Travel continues commonly raised topic stakeholders Concerns were around cost travel increasing particularly regional remote areas Provider queried Modified Monash Model MMM classification often does not reflect actual distance travelled leads situations where potentially undertaken unable claimed due arrangement expense incurred provider Nexus Support Coordination provided example suggesting consideration given to remote surrounded very remote areas For Geraldton (MMM3) been given the NDIS 6 Rating purely based only being Remote (MMM6)

classified regions population nearly drive Perth Karratha estimated of transient nature town over km or hour flight from Perth covers significant stretches Very Remote requires days drive night livestock fatigue flights capped WA State Government’s Regional Airfare Zone Cap with per person way These exist local residents even table: false, set_redactions_used_to_be_here: true

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DISCLOSURE LOG

2022–23 Annual Pricing Review

if the NDIA was trying to build the therapy services market, the sheer cost of flights to get to the northwest is not affordable. Another provider raised concerns that NDIS processes and systems can lead to barriers in claiming such as time taken during plan reviews/renewals or how plans are built. There were some providers’ concerns regarding self-managing NDIS funds around timely payment received from supports delivered on behalf participants their representatives who manage these funds themselves.

Provider peak bodies Ability Roundtable provided a submission about Supported Independent Living (SIL) support based benchmarking survey with one main concern being vacancy management highlighted through this submission:

The report reveals an increase over past two years SIL vacancies median increased from %% (7) to (10) for year ending(2021). This trend highlights lost accommodation options for SIL participants annually along revenue generation opportunities service providers lose each year due to increasing number vacant positions available within program.

Professional Bodies NDIS price limits inclusive GST had few professional bodies raising concerns including Exercise Sport Scientists Australia ESSA ANZACATA’s submissions suggested:

services like Art Therapy have same pricing limit Audiology Dietitians Physiotherapy Social Work Services included under NDIS Therapies Supports however supply taxable GST is part of overall price limit which decreases effective hourly rate earned by members ANZACATA. Suggests annual review 2021-2022 recognized problem recommended off-plan approach ensure NDIS prices exclusive GST Suggestions raised that NDIS should consider measures taken bolster cyber security scheme-wide ongoing transition PACE Another stakeholder raised need greater clarity participant plans funding particularly regarding non-face-to-face travel cancellations avoid tensions misunderstandings between parties involved in delivery services and receiving funds.

Participants A participant expressed concerns about the current arrangements provider travel reports writing suggesting these costs are too high negatively impacting plan budgets One participant found useful resource NDIS Pricing Arrangements Price Limits Document difficulty navigating document needed assistance understanding how best utilize this information effectively.


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2022-23 Annual Pricing Review

As someone who is blind and needs to use a screen reader app to read digital content, I have found the NDIS price limits document difficult to navigate. As a self- manged participant I am not subject to the pricing caps, but it is nevertheless useful to consult the current pricing caps in the NDIS marketplace.

Appendix B – Domestic and family violence

Research

Australian Bureau of Statistics’ (ABS’s) Personal Safety Report (2021)[3] provides insights into the prevalence of domestic violence and/or emotional abuse in Australia.

  • The data shows that during the year before surveying women experienced violence or emotional abuse from a cohabiting partner:5%[4] Table [16]: CURRENT UTILISATION OF DOMESTIC VIOLENCE LEAVE | Company(Yearofsurvey)| Unique aspects of surve| Average leave usageby employees| Other Data| |-|=|=|== Fair Work Commission|(2021)|(Survey employers across multiple industriesin)(2021)||(7,3employersresponded they had provided DV unpaidleave past years to at least one employee) Bank Queensland(Questionnaire Survey on Leave Use for Employees with Family/Domestic Violence Entitlements 2021)-(2021)|||| Western Australian Government-(2021)-856employees entitled paid/unpaid leave over last three years took up some form of leave average days claimed was 3days only one employee claiming full ten day entitlement. In twelve months August-August total eight hundred sixty nine days taken by all staff.| Up to twenty days paid domestic violence leave is provided to all employees Victorian Government-Qualitative Study (Focus Groups) -(2022)-Up to two weeks paid domestic violence leave is provided to all employees. average use out of the total number of leaves taken in year was five and a half days per person eligible for it. New ZealandGovernment Survey-Questionnaire survey conducted in 2021 -The New Zealand government has legislated domestic violence leave for couple several years ago An informal survey of nineteen thousand employees was undertaken to assess take-up rate of this leave | Average usage under five days out of each employee’s eligibility period| The ABS Personal Safety Report can be accessed here Preliminary data from the National Prevalence and Time Series Tables 1–8 shows that during previous financial year, women experienced violence or emotional abuse from cohabiting partner:5%[4] Stanford(2016)[3]conducted study estimating likelihood taking leave if experiencing violence or abuse approximately fifty three point eight percent female thirty nine point seven male. Potential reason given companies surveyed domestic violence economic aspects

DISCLOSURE LOG

MR25/01967 FOI 24/25-2242 - Annual Pricing Review

  • family leave might not have been widely known or understood by all employees, or may have had an association in terms of using that type of leave.

Appendix C – Non-wage Aged Care reforms

In addition to the 15% increase to relevant wages in Aged Care-related Awards, there are other reforms being introduced to improve the quality of care of those receiving aged care supports. Specifically, the Government has committed to introducing: • mandatory 200 minutes of care time, per resident, per day (including 40 minutes by a Registered Nurse) from October 2023. • mandatory 215 minutes of care time, per resident, per day (including 44 minutes by a Registered Nurse) from October 2024. A recent study by CSIRO in 202134 found one in ten Australian Residential Aged Care Facilities met this recommended number of care time suggested by the Royal Commission. What this will mean is that many aged providers would likely need to hire additional staff to meet these new, mandatory requirements. There is the potential for these changes to have flow on implication to the current and potential future worker pool of support workers to deliver supports to NDIS participants. Additionally, the Federal Government has an ongoing review into Aged Care Quality Standards and are currently consulting on a new model for regulating Aged Care which may spur further reforms aimed at improving the quality-of-service provision to participants receiving aged care supports.35 The NDIA also acknowledges there should be assistance provided by the Government to assist aged care providers with these proposed aged care reforms.