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paper,°’ an accessible easy-read paper,°® and an online form. The NDIA received 546 responses to the online form, 10 responses to the Plain English paper and 2 responses to the easy-read paper. The selection of respondents was not randomised and participants could choose which questions they responded to.

The NDIA promoted the participant consultation options through several channels including:

NDIA website
NDIA news update
NDIS social media
NDIS newsletter
Participant First newsletter.°°

There are over 640,000 NDIS participants across the Scheme. The number of participants who responded to the survey represents less than 1% of all participants. Despite this, the responses provide important insights into participant experiences with pricing.

Table 30 shows the proportion of participants who responded to the consultation questions and how they choose to manage their NDIS funding. It includes a comparison to Agency data on how total Scheme participants manage their funding. Over 85% of participants who responded were self-managed or plan-managed, and a small number were Agency-managed participants. 8% of respondents were mixed-

57 Plain English presents information in a way that helps others to understand the message the first time they read or hear it.

58 Easy Read combines text with layout and imagery to simplify and explain information.

59 Participant First offers an opportunity for participants, families, carers and people within the disability community to share their views about the best ways to improve the NDIS through completing surveys, joining focus groups or taking part in interviews

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managed and 2% reported that they were not sure how they manage their NDIS funding.

Table 30: Online Form Participant Respondents and How They Manage Their Funding

Ways to manage funding	Description	Percentage of survey respondents	Percentage of NDIS participants
Plan-managed	The NDIA provides funding in the participant’s plan to pay for a Plan Manager who pays providers, helps keep track off funds and takes care of financial reporting for the participant.	52%	62%
Self-managed	The NDIA provides the participant with funding so they can access the supports that will best help them pursue their goals.	34%	29%
Agency managed	The NDIA pays providers on the participant’s behalf.	4%	9%
Mix managed	The participant can choose a combination of the three options above. For example, they may choose to self-manage one part of the plan and have the rest managed by the NDIA.	8%	Not available

Source: Participant responses to online form; NDIS, NDIS Quarterly report to disability ministers 31 December 2023, p 49.

Note: 2% of respondents reported that they were not sure how they manage their NDIS funding.

Participant awareness and perception of prices

Participants were asked about their awareness of prices

The NDIA is responsible for empowering participants to exercise choice and control. A key component of empowerment for participants is having access to information and tools to make an informed decision about the services they use, including the prices for those services. For this reason, the NDIA asked participants about their awareness of prices.

A high proportion of participants who responded to the online form reported that they are aware of prices and how to access information about NDIS price limits:

94% of participants reported that they know the price they pay for NDIS services and supports.
90% reported that they are familiar with the NDIS Pricing Arrangements and Price Limits (PAPL). This document assists participants and disability support providers in understanding how price controls for supports and services work in the NDIS.

Participants were asked if they pay the same price as a person who is

not an NDIS participant The NDIA asked participants whether they pay the same prices for their services and supports as people who are not NDIS participants. Around 26% of participants reported that they pay the same price as non-NDIS participants, while 41% reported that they do not, and around 33% were not sure.

Participants who said that they do not pay the same price, were then asked to provide examples of the different prices their provider charges.

Most participants who reported that they do not pay the same price as non-NDIS participants provided examples of the prices they pay being higher:

“I go to the OT, on a sign it states $95 first consultation, $90 thereafter. I am charged $193.99 because | am on NDIS.”

“If | tell a cleaning provider that it is NDIS they charge me about 40% more supposedly for administration. If | pay direct and claim reimbursement it is about 40% cheaper per hour.”

“At a previous Physiotherapy clinic | was paying $105 for a 45 minute appointment, when they found out | was self-managed with NDIS for physiotherapy their price went to the full $193.99 and they stated they needed extra time to write notes and it Was more complex to treat someone on the NDIS - yet for 6 months prior they had been treating me for the same issue.”

A relatively small number of participants provided examples of the prices they pay being lower than non-NDIS participants:

Feedback on whether prices are reasonable was mixed

The NDIA often receives feedback from participants through Ministerial Correspondence and other channels about concerns about pricing. To better understand participant views on and experiences with pricing, participants were asked whether they consider prices are reasonable. Participants were then asked to explain why they chose this answer.

Participant views varied considerably on whether the prices they pay for their services and supports are reasonable. About 42% of respondents reported that they agree or strongly agree that prices are reasonable, while 51% reported that they disagree or strongly disagree and 7% were not sure.

Figure 51 shows that agency-managed participants were slightly more likely to agree that prices are reasonable, while self-managed participants were slightly more likely to disagree that prices are reasonable. Overall, there was relatively little difference in perceptions of reasonableness across the different types of funding management for participants.

Figure 51: Summary of Online Form Participant Responses on Whether Their Prices are Reasonable


Agency-managed	Plan-managed	Self-managed	Mix managed	Agency-managed	Plan-managed	Self-managed
agree/strongly agree	disagree/strongly disagree	I’m not sure	agree/strongly agree	disagree/strongly disagree	I’m not sure	agree/strongly agree

Source: NDIA analysis of submissions

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Participants who agree that prices are reasonable often stated that they are able to shop around and negotiate prices. For example:

“I live in a very rural town. I pay the best prices I can for the services I need. I pay below the NDIS price caps but only because I plan manage my funding.”“I am charged much less than the NDIS price guide and the same rate as non-participants.”“I am self-managed so set a reasonable rate that is below the maximum rate.”“I am self-managed, have the capacity to shop around, negotiate and choose not to support providers who overcharge or use the NDIS price guide to set their prices.“Participants who disagree that prices are reasonable often reported that they have different views about the reasonableness of prices, depending on the specific service or support. For example:

“Some prices are reasonable and others aren’t.”“I think the maximum price for some services is far too generous. For example to employ a support worker day time weekday to help me access community and social activities can cost about $65 per hour. I think $65 is far too much for unskilled work to drive me to an event, wait and drive me home afterwards.“Many participants also reported that they consider extra charges for travel or administrative activities to be unnecessary or too expensive:

“The price would be reasonable if travel and paperwork were included, not charged separately.”“$200/hour (near enough) for allied health services + travel on top seems excessive.”“Providers charge ridiculous amounts of money. Everything is charged, even note writing 15 minutes after every therapy.”## How participants manage their funding and engage with providers on pricing

Many participants choose to self-manage or plan-manage to have more flexibility and control

The NDIA asked participants how they manage their NDIS funding for core supports and therapy supports and why they chose to manage their funding this way. Over 85% of participants who responded to the online form plan-manage or self-manage their NDIS funding. A key theme from participants who self-manage or plan-manage their NDIS funding is that they state they have choice and flexibility to negotiate reasonable prices from providers that meet their needs. At least 20 participants reported that they prefer to have the flexibility to use unregistered providers.

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Comments from participants who self-manage include:

“Full control over who I employ or hire, much better value for money, ability to negotiate rates and conditions.”

“Because I can stretch my funding further in core supports by still paying a fair price, but I’m not governed by a ‘price guide’. My support workers are privately hired by me.”

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Participants who discuss and agree on prices with their provider were much more likely to agree or strongly agree that prices are reasonable (71%). Participants who said their provider tells them the NDIA decides what prices they have to charge were much less likely to agree or strongly agree that prices are reasonable (20%).

The NDIA also asked participants how their provider tells them about price changes and policy changes for their services and supports. The most common reported method for communicating these changes was email, followed by letter, plan manager, SMS/text message and in-person.

Information and education for participants about the NDIS market

As discussed above, a key component of empowerment for participants is having access to information and tools to make a more informed decision about the services they use. The NDIA considers there is benefit in improving the tools available to participants to ensure they have access to accurate information about their rights as consumers.

Several participants described how they benefit from shopping around to find providers that best meet their needs and negotiating prices and service conditions that work for them. However, not all participants have been able to do this. Participants reported that some providers are not willing to negotiate and, in some cases, provide them with incorrect information about the role of the price limits. For example:

“All supports and services I come across that deal with mainly NDIS participants charge the maximum rate and they say that is the price that NDIS say they HAVE TO CHARGE, they don’t get that is the maximum rate and that NDIS really want them to charge less. A friend tried to negotiate with the same provider that | use and she told me that she thought it was rude of the participant to devalue her time.”“Many support workers charge the top rate listed in the pricing arrangement and think that is what NDIS says they should be paid. Many of them don’t understand that it is a suggestion/ maximum price one can charge and they DO NOT allow negotiations.

“As a self-managing participant | am supposed to be able to negotiate with providers. | am never given this opportunity. | am charged the highest amount possible. The idea of negotiation, particularly in areas where service providers are limited to a few, is just not realistic. Providers know there is an upper limit to what they can pay and they charge accordingly.”“Providers are allowed to charge up to the price limits. However, when providers do so, the NDIA considers that they should clearly communicate to participants that charging at the price limit is a business decision, not a requirement imposed by the NDIA. The PAPL states that “providers should not indicate in any way to participants

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that the prices that they charge are set by the NDIA”.60 Similarly, the PAPL notes that “the NDIA does not set the prices that providers charge”.61 When providers give incorrect information to participants about the role of the price limits, this may mislead participants and discourage them from attempting to negotiate prices for their services and supports in future.

For this reason, the NDIA considers it is important that participants are well equipped with accessible information about the price limits and their rights to negotiate with providers. A targeted capacity-building education campaign for both participants and providers about these rights, with relevant information published on the NDIS website in an accessible format could help to achieve this. Ultimately, timely and reliable information sharing will empower participants to make informed decisions and ease information asymmetries.

Multiple cross-agency initiatives have been established to improve outcomes for participants and to ensure that providers are doing the right thing:

The Fraud Fusion Taskforce started in November 2022. It is a partnership between the NDIA, Services Australia and 14 other government agencies including the NDIS Quality and Safeguards Commission, the Australian Federal Police and the Australian Criminal Intelligence Commission. The Taskforce aims to improve how government agencies work together to quickly detect, resolve and prevent fraud, while reducing the impacts of fraud on NDIS participants.62
The NDIS Provider and Worker Registration Taskforce will provide expert advice to Government on the best approach to overhaul the current

[60] NDIS Pricing Arrangements and Price Limits 2023-24, p 10. [61] NDIS, Explaining the NDIS Pricing Arrangements and Price Limits (PAPL), p 1. [62] NDIS, Fraud Fusion Taskforce, accessed 3 April 2024.

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registration system for providers, while maintaining choice and control for participants - as recommended by the NDIS Review.

The Fair Price Taskforce to crackdown on unfair price hikes for NDIS participants is now operational. The ACCC will chair the taskforce, together with the NDIS Quality and Safeguards Commission and the National Disability Insurance Agency. The NDIS Commission will tackle illegal overcharging of NDIS participants. The ACCC will focus on investigating and clamping down on misleading conduct, unfair contract terms and anti-competitive agreements that might impact NDIS participants, while supporting the taskforce’s work.

Learnings from the participant consultation will be shared with the relevant taskforces to ensure that providers are giving correct information to participants about their rights and the role of the NDIS price limits.

8.6 How the NDIA has considered participant feedback throughout the APR

The NDIA has considered feedback from both participants and providers when making recommendations about the NDIS’s price control framework. Other chapters in this report include summaries of feedback received from participants and providers, and explain how we have considered this feedback when making recommendations. Two key areas that participants were consulted on include:

Support coordination - The NDIA also asked participants about their experiences with support coordination, including their level of satisfaction with their support coordinator. Participant responses to these questions are discussed in Chapter 6.

[63] NDIS, New Taskforce to help improve NDIS registration, accessed 3 April 2024.

[64] Ministers for the Department of Social Services, Cracking down on overcharging of NDIS participants, 24 March 2024.

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Cancellation policies - To better understand participant experiences with provider cancellation policies, the NDIA asked participants about their awareness of cancellation policies, as well as how these policies vary across their services supports. Chapter 7 discusses participant feedback on these issues in more detail and recommendations resulting from that feedback.

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Appendix A - Feedback from the Provider Consultation Paper

Overview

The 2023-24 APR consultation commenced on 25 January 2024. Provider submissions closed AEST 11:59pm on 10 March 2024 and participant submissions closed AEST 11:59pm on 17 March 2024. The Provider and Participant Consultation Papers included a series of guiding questions.

A total of 912 submissions were received in response to the consultation papers. Of these, 559 submissions were in response to the Participant Consultation. Participant submissions are discussed in detail in Chapter 3.

The remaining 353 submissions were in response to the Provider Consultation Paper and were received from a range of stakeholders:

259 from a range of provider organisations
60 from employees/workers
15 from professional associations
13 from provider peak bodies
3 from advocacy groups
2 from workers unions
1 from an educational institution

Market environment and influences: changing economic conditions, business risks and vacancies

Adapting to changing economic conditions

The Provider Consultation Paper sought to understand the segment of the care and support sector provider organisations operate in. It also undertook to inform the NDIA’s understanding of the impact of recent economic conditions (e.g. inflation and rising interest rates) on providers, the primary business risks faced by them and how these risks are being managed, as well as vacancy rates (as a proportion of total planned workforce).

Providers A total of 217 provider submissions responded to the questions about economic conditions, business risks and staff vacancies.

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Almost all providers reported increases in costs. Providers highlighted general increases in wage costs in a highly competitive labour market, as well increases in insurances, rent, travel costs, utilities, and other operating expenses. Several providers attributed these increasing costs to reduced profit margins, and expressed concern about their ongoing financial viability as NDIS providers. Many providers noted that the NDIS price limits have not increased for a number of years.

Providers reported a range of approaches to adapting their businesses in response to these changing economic conditions, including:

increasing prices to the NDIS price limit for NDIS participants
increasing prices for non-NDIS clients
adapting billing practices e.g. charging NDIS participants for services previously not charged for, such as preparation and travel
adapting the services they deliver e.g. limiting the geographic area(s) in which they operate, reducing the frequency and types of supports delivered, providing services differently (e.g. use of tele-health), through to ceasing to provide select services altogether
pursuing efficiencies from organisational restructures or increasing expectations of billable hours (i.e. increased utilisation rates)
reducing investment, by deferring capital expenditure
absorbing cost increases e.g. through salary freezes
operating at a loss and/or cross subsidising losses through other revenue streams.

One provider stated that:

“Inflation and rising interest rates have impacted my business by a 20% rise, and I have had to respond by increasing my client intake, working before and after school and longer than 10 hours days, since increasing the rate for therapy has NOT been an option.”`

Provider peak bodies

Provider peak bodies raised similar themes about challenging economic conditions where costs have increased, and profitability is reduced. Respondents noted that these challenges are likely to impact the quality of services offered by providers, with less investment in staff training and other quality-enhancing initiatives. It was also noted that many businesses are operating at a loss, which may lead to market exits.

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Professional bodies

Professional bodies also reported rising costs and financial pressures. It was noted that some providers who previously charged below the NDIS price limits, are now increasing their prices up to the price limits. Professional bodies reported instances where providers are considering moving to self-managed participants so they can charge above the price limits to cover their costs. A professional body reported that many providers are conscious of the impact of a challenging economic environment on participants and have sought to minimise any price increases by bearing the cost themselves.

9.2.2 Primary business risks

Providers

Financial sustainability was identified as the primary business risk by 64% of provider responses. This was raised when responding to questions about changing economic conditions.

Providers also raised challenges with staff recruitment and retention as a key business risk. Providers reported a shortage of practitioners, increasing wage costs and challenges with retaining staff due to competition from other sectors, as well as staff leaving to become unregistered sole-trader providers:

“The biggest risk to my business is that I will be unable to sustain a workforce to support NDIS participants due to the rise in expenses namely practitioner wages (including superannuation increases) and the cost to recruit quality candidates, whilst also holding onto quality employees.”

Providers also raised a wide range of other themes, including risks arising from the amount of time spent on NDIS administrative tasks, registration costs and uncertainty about ongoing reforms to the NDIS.

Provider peak bodies

Peak bodies raised concerns about the costs of NDIS registration and noted that some members report considering de-registering.

Professional bodies

Similarly, professional bodies also stated the administrative burden of NDIS registration as a business risk, as well as financial sustainability and uncertainty about broader changes within the NDIS. Professional burnout and delays in receiving payment for services relating to assistive technology were also raised as business risks.

Staff Vacancies

Providers

Many provider submissions indicated they currently have vacancies. Reported vacancy rates varied considerably, ranging from less than 5% to more than 50%.

High staff turnover was reported in many submissions, as well as broader challenges with recruitment and retention. Several providers reported an operating environment where staff leave to become independent/sole-trader providers or take up work in other sectors where they may receive higher wages. A number of providers reported increasing costs associated with salaries and wages to retain staff, or additional costs associated with recruitment (e.g., advertising and recruitment agency costs). For example:

“We have experienced a significant staffing shortage over the past 18 months. Our workforce operating across disability support and community aged care support has reduced from 70 staff to 50 staff over this time. Like many other industries the disability and aged care sector has been hit hard by staffing shortages, the impact of this has been harder still in rural areas where there is a smaller population to draw from and a lack of transport and housing to attract people from out of the area.”

Professional bodies

Professional bodies reported a wide range of vacancies among their members, ranging from no vacancies to up to 80%. It was also noted that in some cases, even though their members have vacancies, they have ceased recruiting due to difficulties with finding staff.

Disability Support Worker (DSW) Cost Model

The Provider Consultation Paper sought stakeholder views on the DSW Cost Model assumptions about organisational overheads and operating costs. Providers were also asked about impacts of the 15% wage increase under the Aged Care Award that took effect from 30 June 2023. A total of 79 provider submissions, five provider peak bodies and one union organisation responded to questions about the DSW Cost Model.

Alignment of Disability Support Worker Cost Model assumptions with provider’s corporate and operational overheads.

Providers

Almost all provider submissions to the DSW questions noted that the assumptions in the DSW Cost Model do not reflect their actual costs. Only 2 of the 79 submissions from providers indicated that the model’s assumptions align with their costs.

Provider submissions raised concerns about financial viability under the model’s costings, suggesting it does not reflect actual costs and requires providers to absorb cost increases.

The cost model does not fully account for the complete cost of a billable hour of support, considering base pay, shift loadings, leave entitlements, salary on costs, employee allowances, operational overheads (including supervision costs, utilisation costs, and workers’ compensation costs), corporate overheads, and margin.

Many providers reported that their operational and corporate overheads are generally higher than the percentage assumed in the DSW Cost Model. Key reported differences include:

worker’s compensation rates and insurances
costs associated with utilisation rates, a casualised workforce and in some cases, a reliance on agency staff
general operational overhead percentages exceeding levels assumed in the DSW Cost Model
quality and safeguarding activities, including registration and audit costs.

The one size fits all approach does not recognise the different living environments, diversity, and complexity of supports across participants in the scheme. The price limit is the same for a sole trader delivering in-home support as it is to for a shared 24/7 living arrangement irrespective of the number of people and their needs, and the complexity of support.

Provider peak bodies

Ability Roundtable provided its Financial and Workforce Benchmarking analysis, which was undertaken in conjunction with 63 DSW registered NDIS providers. A mix of for-profit and not-for-profit providers participated, from both metropolitan and regional areas.

For the organisations included in the benchmarking analysis:

average profitability was reported at -2.1%.
over 60% of respondents reported three years of consecutive losses since the 2021-22 financial year (data showed a median loss of 5.9% in 2021-22 and 4.9% in 2022-23).
there is a 10.9% variance between the DSW Cost Model and actual reported costs to deliver support.

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‘there is a growing gap between the NDIA DSW Cost Model assumptions and the actual cost of service provision”.

Other peak bodies reiterated that the DSW Cost model does not align with operational and organisational overheads, calling for increases in core supports delivered by DSW.

“Cost model does not take into account the funding nature with donations or reserves, complexity of services provided, provider organisation size or quality and safeguarding requirements.”

Unions

The Australian Services Union stated there needs to be clearer rules regarding pay and classifications, portable entitlements to paid and other types of leave and sufficient paid time in rosters for training. Similarly, the Health Services Union highlighted a lack of clarity in the current model for how the NDIS price limits for work performed before and after a sleepover.

9.3.2 Range of SCHADS Award classifications under which staff are employed and distribution of permanent full time, part time and casual employment

The Provider Consultation Paper asked about the range of SCHADS Award classifications under which provider organisations employ DSWs and how they are distributed across permanent full-time, permanent part-time and casual employment.

Providers reported a wide range of SCHADS Award classifications from Level 1 to Level 8. For example:

We have SCHADS employees from level 2 through to level 6, with one manager at level 8.

In our organisation DSW are generally paid at level 2.4 or Level 3. Service coordinators at level 4.2.

The proportion of reported DSWs employed casually ranged from 12% to 100%. About half of provider submissions reported that 70% or more of their DSW workforce is employed casually. Several providers responded that DSWs prefer to work casually, as they get paid more and have more flexibility, even if it is at the cost of paid leave.

Several responses highlighted the need for the cost model to reflect the actual costs related to shift work, leave loading and public holidays.

Reasons cited for [DSWs preferencing casual employment conditions]: pursuit of higher salaries, more flexibility. This also comes with additional cost overheads associated with re-rostering required for a more transient workforce.

Impacts of the Aged Care Award 15% wage increase from June 2023 on recruitment and retention of Disability Support Workers

Providers

Provider submissions reported mixed impacts from the 15% increase to the Aged Care award, with some providers describing no tangible impact and others experiencing significant workforce challenges. Many providers reported general challenges with finding suitable workers with the right skills and experience. Other providers reported that the Aged Care Award increase has put upward pressure on wages, with many of these providers reporting paying above-award wages to attract DSWs. It was reported that the upward pressure on wages contributes to existing workforce challenges with high turnover rates and associated recruitment costs, as well as competition from staff becoming independent DSWs.

The increased wage and subsequent increased appeal of the Aged Care sector has made it even more difficult to attract employees to the Disability sector. There are greater opportunities for them to gain Permanent F/T employment in the Aged Care sector.

Competitiveness in wages has notably increased since the 15% wage increase in Aged Care in July 2023.

In March 2024, it was announced that aged care workers will receive a further increase of between 18.2% and 28.5%, inclusive of the 15% already ordered, depending on their skill and qualification level.

9.4 Therapy Supports

The Provider Consultation Paper asked several questions about providing therapy supports, including changes in the costs of delivering services and questions about the differences between providing therapy supports to NDIS and non-NDIS clients.

There were 178 provider submissions received relating to therapy supports, 13 from professional bodies, one from a union and a small number from provider peak bodies. Through the APR online form and Participant consultation paper, 142 participants also provided feedback on therapy supports.

9.4.1 Changes in the costs of delivering services

The Provider Consultation Paper asked providers about significant changes in the costs of delivering Therapy support services.

Providers

About 87% of provider submissions reported increases in the costs of delivering therapy supports and services. Providers noted increases in wage costs (including increasing staff wages, keeping up with Allied Health awards and professional development costs) and costs associated with recruitment and retention. Providers also reported increases in business expenses such as rent, utilities, office supplies, insurance, workers compensation premiums and travel expenses.

Provider peak bodies

Ability Roundtable responded to the consultation questions on therapy supports and included an updated Allied Health Cost Model for NDIS-funded services from Deloitte Access Economics. The model estimates the respective services costs of 13

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large therapy providers.® The model indicates that the current NDIS price limits are lower than the actual and projected costs of delivering therapy supports:

There is a 12.9% difference between the projected fully loaded cost to deliver an hour of therapy supports and the current NDIA Price Limit for the 2024-25 financial year for the four major allied health disciplines.
For Psychology Services, there is a 16.6% difference between the fully loaded cost to deliver an hour of Psychology supports, when compared to the current NDIA Price Limit for the 2024- 25 financial year.

Professional bodies

Allied Health Professionals Australia submitted that the price limits for therapy should be raised to reflect cumulative indexation since 1 July 2019 and suggested that from 2025, price limits for therapy supports should be automatically indexed.

Allied Health Professions Australia described rising business costs (e.g. wage market rates, rent and utilities, supplies, fuel, consumables and equipment, travel, insurance and other operational expenses).

“Our members’ therapy support businesses tend to operate at a small scale, and they therefore have limited infrastructure and resources and operate on thin margins. There is little possibility of further ‘efficiencies’ within small and solo practices, without compromising on the amount or quality of service.”

Similarly, Australian Physiotherapy Association noted that its members find themselves struggling to balance the need to support their staff in a context of rising cost of living by increasing wages while trying to keep their own costs under control.

66 These participating provider organisations represent an equivalent of 18% revenue across the therapy supports market.

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9.4.2 NDIS providers offering support for early childhood supports and to non-NDIS clients — prices, appointment durations and fee-setting considerations

The Provider Consultation Paper asked providers if they offer therapy supports/early childhood supports to non-NDIS participants. Providers were asked about the proportion of NDIS participants and non-NDIS participants they service, the typical duration of appointments, and if there are variations in prices. Providers were also asked how they determine the hourly rate charged for NDIS participants and what factors they consider when setting different rates.

Providers

The majority of provider submissions responding to this topic reported providing therapy support services to NDIS clients and other segments of the care and support economy (such as private clients or other insurance schemes). The proportion of NDIS participants serviced by these participants ranged from 25% to almost 100%, with more than half of these providers having a client base that was 70% or more NDIS participants.®”

Appointment durations reported by providers were in many cases the same for NDIS participants as non-NDIS clients. Many providers explain that appointment durations are tailored to the needs of a client, regardless of whether they are an NDIS participant or not. Other providers reported differences in appointment duration due to the complexity or reporting requirements for NDIS participants, and a small number of providers indicated that they billed NDIS participants for this non-face-to-

face time.

“Our appointment length is determined in accordance with the principles of evidence-based practice, considering a client’s needs/goals, family commitments and research evidence as to the intensity and frequency of intervention. Therefore, there is no

67 Noting that some providers support only NDIS participants.

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distinction in appointment duration based on whether a client is an NDIS participant or private client.”

“30 or 60 minutes non-NDIS. 60 minutes for NDIS clients who are usually more complex with multiple co-morbidities and increased liaison time with involved parties including other therapists, SC, equipment suppliers, builders etc.”

Provider submissions outlined a range of pricing practices. Most providers reported charging NDIS participants at the price limit, while a small number reported charging below the price limit.

Many of these providers charge non-NDIS participants the same fees as NDIS participants. Other providers reported a price difference between NDIS participants and non-NDIS clients, with some charging more for NDIS participants and some charging less. Reasons for charging different prices varied widely. For example, some providers reported:

NDIS participant complexity or additional administrative costs associated with providing services to NDIS participants as a reason for charging NDIS participants more.
The lack of change in NDIS therapy support price limits over the last five years as a reason for charging non-NDIS clients more than NDIS participants.

Professional bodies

Feedback from professional bodies relating to differences in appointment durations was mixed. For example, the Australian Psychological Society stated the median duration of psychological appointments for its members is 60 minutes for both NDIS participants and non-NDIS clients.

The Orthotics and Prosthetics in Australia noted that while some considerations for fee-setting are the same, there are also NDIS-specific aspects:

“The main difference is the report writing component for NDIS participants which is significantly more time burdensome and almost triple what is required by most non-NDIS clients.”

9.4.3 Unique costs in providing early childhood supports for NDIS participants

The Provider Consultation Paper asked providers about unique costs of providing early childhood supports for NDIS participants.

Providers

Providers outlined a range of unique costs of providing early childhood supports, with 85 (or 33%) of provider submissions responding to this question. Most providers

describe this group of NDIS participants as more complex, compared to other early childhood clients who are not eligible for supports under the NDIS.

When describing early childhood supports for NDIS participants as more intensive and requiring more time, the following additional activities and costs were noted:

collaboration and liaison as part of team-based approaches, with an appointed ‘Key Worker’®
delivering supports in natural environments, such as at home or in school settings, which requires travel that can exceeds established caps
specialist skills and professional development needs, often resulting in a need to pay higher salaries
mandatory reporting obligations, such as writing reports related to funding allocation decisions, risk assessments, reporting to the NDIS Safeguards Commission and making Child Safe notifications.

Professional bodies

Professional bodies noted similar costs of providing early childhood supports for NDIS participants. For example, the Australian Physiotherapy Association described liaison and communication with the care network, support to the family, the expertise and complexity required, extended appointments, the service environment and administrative load.

Dieticians Australia also noted other unique considerations when providing early childhood supports, such as the requirement for specialised training materials and resources, and tools designed specifically for young children with disability:

68 Under the eight principles of best-practice early childhood intervention, a family works together with professionals to form a team around the child, communicating and sharing information, knowledge and skills. One main person, called a key worker, works with the family. NDIS, Early Childhood Approach — a guide for professionals, p 4.

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Support Coordination

The Provider Consultation Paper asked support coordinators if there have been significant changes to the costs of delivering services over the past 12 months.

About 55 (or 21%) of providers made submissions relating to support coordination, as did a small number from provider peak bodies and professional bodies.

Providers

Most support coordination providers reported increases in the costs of delivering services. Common themes from those submissions include that operating costs have increased (such as wages and salaries, rent, fuel and insurance), while NDIS price limits for support coordination have been held constant for several years.

Many providers noted that they face difficulties in attracting and retaining suitable staff, reporting that there is pressure to increase wages to keep up with the rising cost of living and to remain competitive with comparable positions in similar industries. Several providers described doing work that is often unbilled but necessary, which they consider is not sufficiently accounted for in the current price limits for support coordination, including:

activities related to onboarding new clients for support coordination (contacting the NDIA, accessing portals, understanding the client’s needs, executing service agreements and doing risk assessments).
activities associated with transitioning to the new PACE portal.
administrative activities when a participant dies.

Other providers noted that because the price limits have not kept pace with rising costs, their financial sustainability is under pressure.

Provider peak bodies

Peak bodies raised concerns about the current price limits constraining the quality of support coordination services and noted that the price limits have not increased in recent years. Peak bodies also raised concerns about the price limits not sufficiently accounting for the amount of non-face to face time support coordinators incur.

Unions

The Health Services Union noted that the NDIS Review has recommended phasing out support coordination and introducing navigators. Until navigators are introduced, the Health Services Union suggests that transitional increases to support coordination price limits are critical to ensure support coordinator wages keep up with inflation and increased costs.

Cancellation Policies

The Provider Consultation Paper asked several questions about provider cancellation policies, including:

What is your cancellation policy for NDIS participants? Is it different for non-NDIS clients? If so, why?
How often do you face short-notice cancellations or no shows and on average and how frequently do you claim for these instances monthly? What approach does your organisation take when a participant has an unusually high frequency of cancellations?
What service offering does your business have as an alternative to short notice cancellations?

Of the 353 provider submissions received, 121 (or 34%) responded to questions relating to cancellation policies, frequency of short-notice cancellations and alternative service offerings aimed at reducing cancellations.

Provider variances in cancellation policies for NDIS participants and non-NDIS clients

Providers Most provider submissions reported that they have no differences in their cancellation policies for NDIS and non-NDIS clients, with a small number of providers reporting that their cancellation policy is different.

The majority of therapy support providers described adopting a 2-day cancellation policy rather than the 7-day policy. Providers noted that 48-hours is an industry standard across the Allied Health sectors, and that they do not want to lose clients by adopting a different policy. In general, there was wide variation in reported cancellation policies, with the most commonly cited cancellation policies being 2-hours, 24-hour or 72-hours.

“Our cancellation policy has a notification period of 48 hours and charges 90% of fee for NDIS participants. It is not different for non-NDIS participants, except in exceptional circumstances (family emergencies eg, hospitalisation, natural disasters, extreme weather events, significant financial hardship).”

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Provider peak bodies

Provider peak bodies reported favouring retention of the current 7-day cancellation policy arrangements. Peak bodies noted that under the current SCHADS Award, payment to employees is required for cancellations within 7 days. Peak bodies noted that providers try to find alternative work for the employee, but often this work is administrative and unbillable because existing billable services are usually already rostered to other employees.

Professional bodies

Provider professional bodies described the diversity of cancellation policies across the sector. A large peak body reported that a third of their members adopt a 24-hour or 48-hour cancellation policy. About 15% of their members stated they do not have a cancellation policy, as cancellations are very infrequent.

Unions

Submissions from Union organisations representing the DSW workforce suggested the 7-day cancellation policy helps ensure retention of the workforce and assists to increase participants’ choice of workers.

Frequency and average of short-notice cancellations and monthly claim averages

Providers

There was considerable variation in reported frequencies of short notice cancellations and monthly claim averages. It was noted that seasonal weather impacts the frequency of cancellations (e.g., the winter flu season brings a higher rate of cancellations).

Provider peak bodies

The Australian Psychological Society noted that cancellations by NDIS participants were relatively infrequent, with two-thirds of members reporting that they occurred in less than 10% of scheduled appointments. A further 29% noted that they occurred occasionally, between 10-30% of scheduled appointments.

Other provider peak bodies also noted that short notice cancellations are relatively infrequent, with some reporting less than 10% frequency.

Provider approaches for unusually high frequency of cancellations and alternative service offerings to reduce cancellations

Providers

Most providers reported that they try to provide participants with a range of different alternative service offerings when they need to cancel their appointment, such as telehealth, arranging a home visit or re-booking the appointment. Several providers also describe sending SMS text messages and appointment calendar reminders to participants the day before an appointment to help reduce the frequency of cancellations. In addition, most provider submissions acknowledged that the unique needs of each client need to be considered when determining a suitable alternative.

Alternatives MUST relate to the best practice for that family and child…switch to telehealth. In the early years, children getting sick is a regular reason for cancellations. Telehealth may not be an option…We offer other non-client facing activities in the same timeslot, development of program materials, complete upcoming service summaries and reports for funding reviews, create supporting therapy resources for the school or home or use the time to collaborate with other team members, teachers etc.

Professional bodies

Provider professional bodies stated their members offer telehealth services, phone services, or other non-face-to-face services as an alternative to charging a cancellation fee. These alternatives include using the cancelled appointment time to develop resources (e.g. visual aids and materials), write reports, reach out to the family to offer support, liaise with stakeholders and arrange meetings.

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