Comparable government and funding schemes

The NDIA compared therapy price limits and arrangements across other comparable government schemes and funding. Overall, the analysis shows that NDIS price limits are broadly in line with other comparable schemes for most types of therapies.

The NDIA collaborated with 16 Commonwealth and State Schemes to obtain their therapy pricing. Responses from 13 schemes were received. For a complete overview of participating scheme, see section 2.4 Consultation overview.

To calculate the effective hourly price limit, NDIA sought information about the regulated length of therapy sessions (for example, the NDIS price limits for therapy are per hour). For comparability, the NDIA generally used standard or subsequent consultations where possible, noting that many schemes have differentiated items and/or pricing for initial consultations and standard/extended consultations.

The NDIA were able to calculate the effective hourly price where the length of a session was provided (for example, price per 20 minutes) or as an average session time, based on the observed length of sessions. In some cases, the length of a session was based on a minimum or maximum length (for example, price for at least 20 minutes). In these situations, some assumptions were made by the NDIA to calculate an hourly price, based on available information. If the length of a session (or an approximation) was not provided, the NDIA were unable to calculate the effective hourly price, and not able to directly compare prices, so these were excluded from the analysis.

As Figure 31 shows, the current NDIS price limits (shown as orange dots) are broadly within the range of the effective hourly rates paid by other schemes for the most common therapy supports, after considering duration of service. Information received indicates that over the past year, most schemes have increased prices for the therapy supports that they provide. Price changes vary by scheme and therapy support, but typically fall between 2% and 8%. This appears to have put NDIS into the middle range for some therapies, such as Audiologists, Counsellors, Exercise Physiologists and Psychologists, acknowledging ranges can be quite broad once scheme prices are turned into a comparable hourly price.

The main Medicare Benefits Schedule (MBS) items for allied health have a scheduled fee of $68.55 per 20 minutes session. This equates to an effective hourly rate of $205.65 which is higher than the NDIS hourly price limit. The Commonwealth funding (MBS benefit) for the hour is 85% ($174.80), but co-payments are common in the MBS and the scheduled fee is a better estimate of the total cost of the support.

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Figure 31: Comparison of NDIS price limits to other government schemes

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

This box and whisker chart shows the minimum value, first quartile, mean, median, third quartile and maximum value of a data set.

The box contains the range of the middle half (50%) of the data.
Mean is indicated by the cross (X) on the box.
Horizontal line (middle line) of the box represents the median or middle number.
The bottom line of the box represents the median of the bottom half or 1st quartile.
The top line of the box represents the median of the top half or 3rd quartile.
Whiskers are the lines extending from the ends of the box and these indicate variability outside the lower and upper quartiles, that is, the minimum and maximum values.

	Psychologist	Counsellor	Physiotherapist	Exercise Physiologist	Dietitian
	redacted: s22(1)(a)(ii) - irrelevant material	redacted: s22(1)(a)(ii) - irrelevant material	redacted: s22(1)(a)(ii) - irrelevant material	redacted: s22(1)(a)(ii) - irrelevant material	redacted: s22(1)(a)(ii) - irrelevant material

Source: NDIS calculations of comparable prices of other government funding schemes

Note: All NDIS price limits are shown in purple text. For some therapy supports, the NDIS has two different price limits. One price limit is for the eastern states (NSW, VIC, QLD, ACT) and the other is for all other states (WA, SA, TAS, NT).

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Private billing rates

This section analyses a data set of 1,791 private billing rates for several NDIS-related weekday in-room therapy services. The private billing dataset was compiled by the NDIA by scanning provider websites across Australia. Prices for weekend, initial consultations and telehealth consultations were excluded from the dataset, as well as some outliers.

The sample has been derived from the private billing analysis conducted in the 2021-22 Annual Pricing Review (4,014 in-scope observations). The NDIA tried to replicate the same sample during the 2022-23 Annual Pricing Review (2,857 in-scope observations). For reference to last year’s analysis, 1,167 observations dropped out of the last years sample of 2,857.

For greater representation in certain segments of the sample, observations were expanded in certain states (NSW, SA, NT and ACT) to ensure there was enough observations for significant results. This led to over 200 provider websites randomly sampled for relevant pricing, with many not having available or comparable pricing. In total, this provided a sample size of 1,791 observations for the 2023-24 period. The sample size is still considered sufficient for the purpose of pricing benchmarking. In the absence of a requirement to publish pricing or a database of comparable, time-based therapeutic sessions, these hinder the long-term viability of this sampling method. The NDIA intends to consider measures to improve this process in coming years.

The private billing rates were converted to effective hourly rates based on the length of consultation, for more direct comparison to the applicable NDIS price limit. About 30% of the sample included billing rates from non-metropolitan areas (considered as Modified Monash Model (MMM) areas 4 to 7).

The study excluded outliers where the value of hourly rate was either greater than Quartile 3 +1.5Interquartile or was smaller than Quartile 1 – 1.5Interquartile.

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In the analysed sample of therapy services, the most frequently represented therapists were Physiotherapists, making up 20.5% of the dataset, followed by Psychologists at 15.4%, Clinical Psychologists at 10.1%, and Dietitians at 8.9%. For most therapy types, the dataset includes at least 80 observations, with the exceptions being Art Therapists (26 observations), Music Therapists (39 observations), and Social Workers (45 observations).

The diversity and overlap in pricing across different therapy types are illustrated in Figure 32, showing the range and commonalities in billing rates among the various services. There appears to be some multi-modal distributions for several types of therapies, where there is a cluster of prices in the sample around different price points.

Figure 32: Distribution of Private Billing Rates by Therapy Types

| State | Counselling | Exercise Physiology | Art Therapy | Podiatry | Music Therapy | Dietitics | Occupational Therapy | Social Worker | Speech Pathology | Audiology | Physiotherapy | Psychology | Psychology - Clinical | |—|—|—|—|—|—|—|—|—|—|—|—|—| | 100 | 200 | 300 | 400 |

The distribution of sample observations geographically leaned more towards VIC, 34% of the sample, and QLD, with 27%, indicating an underrepresentation of therapists from NSW, which accounted for only 20%, compared to its share of the

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NDIS market (31% of total NDIS therapy claims in the six months to December 2023). The NT was the only state or territory with fewer than 30 observations (12).

Figure 33 shows the distribution of private billing rates across different states and territories, revealing substantial overlap and variance. From the analysis, certain states, and territories, including the NT and TAS, exhibited a variety of trends in pricing distribution.

Figure 33: Distribution of Private Billing Rates by State and Territory

State	WA	VIC	NSW	QLD	NT	SA	TAS	ACT
Dollars per hour

Table 21 shows an overview of the distribution statistics for the private billing rates sampled. On average, the effective hourly rate for therapists providing in-room services on weekdays was $195.6, with a median rate closely following at $194. The data set revealed a wide range of billing rates, from a minimum of $85 to a maximum of $396.

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Table 21: Summary Statistics of Private Billing Rate Sample, by Therapy Type

Type of Therapy	Count	Mean	Standard Deviation	Min	25th percentile	Median	75th percentile	Max	NDIS price limit
Art Therapy	26	$154.5	$30.6	$100.0	$135.0	$147.5	$178.8	$216.0	$193.99
Audiology	86	$194.5	$21.7	$156.7	$180.0	$190.0	$210.0	$240.0	$193.99
Counselling	161	$153.1	$41.2	$85.0	$120.0	$150.0	$179.5	$305.5	$156.16
Dietetics	165	$175.3	$51.2	$92.5	$132.0	$170.0	$200.0	$320.0	$193.99
Exercise Physiology	115	$154.1	$39.2	$93.3	$120.0	$159.0	$180.0	$265.3	$166.99
Music Therapy	39	$166.0	$36.7	$90.4	$120.0	$180.8	$194.0	$233.3	$193.99
Occupational Therapy	128	$181.0	$38.4	$93.3	$150.0	$194.0	$194.0	$291.0	$193.99
Physiotherapy	364	$202.7	$50.2	$90.0	$165.0	$200.0	$240.0	$324.0	$193.99/$224.62*
Podiatry	86	$157.9	$46.8	$90.0	$120.0	$150.0	$180.0	$315.0	$193.99
Psychology	281	$228.6	$45.7	$120.0	$196.5	$228.0	$254.2	$380.0	$214.41/$234.83*
Psychology - Clinical	179	$260.3	$39.6	$165.3	$230.0	$255.0	$284.4	$396.0	$214.41/$234.83*
Social Worker	47	$184.8	$48.0	$90.0	$160.0	$180.0	$218.2	$270.0	$193.99
Speech Pathology	113	$192.7	$65.6	$95.0	$163.3	$193.3	$194.0	$380.0	$193.99
Total	1,791	$195.6	$56.0	$85.0	$158.0	$194.0	$230.0	$396.0	Varies

Note: * VIC, NSW, QLD, ACT. ** WA, SA, TAS, NT

Figure 34 and Figure 35 compare the average private billing rates for various therapy types to the current NDIS price limits. The findings indicate:

The average billing rates for clinical psychology and psychology in all states and territories exceed the NDIS price limits.

Therapies such as Speech Pathology, Audiology, Occupational Therapy, Dietetics, Social Work, Exercise Physiology, and Counselling have billing rates that are 90% or more of their NDIS price limits.

Conversely, Art Therapy (78.7%), Podiatry (81.4%), and Music Therapy (85.6%) show average billing rates that fall significantly below their NDIS price limits.

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Figure 34: Average Private Billing Rate Compared to the NDIS Price Limit (Dollar Value)

	NDIS price limit	Average private billing rate
Psychology - Clinical (WA, SA, TAS & NT)
Psychology - Clinical (NSW, VIC, QLD & ACT)
Psychology (WA, SA, TAS & NT)
Psychology (NSW, VIC, QLD & ACT)
Physiotherapy (WA, SA, TAS & NT)
Physiotherapy (NSW, VIC, QLD & ACT)
Audiology
Speech Pathology
Occupational Therapy
Music Therapy
Social Worker
Dietitics
Podiatry
Art Therapy
Exercise Physiology
Counselling

$50 $100 $150 $200 $250 $300

Figure 35: Average Private Billing Rate as a percentage of NDIS price limit

Mean private billing rate as a % of NDIS price limit

	0%	25%	50%	75%	100%	125%	150%
Psychology - Clinical (NSW, VIC, QLD & ACT)
Psychology - Clinical (WA, SA, TAS & NT)
Psychology (NSW, VIC, QLD & ACT)
Psychology
Physiotherapy (NSW, VIC, QLD & ACT)
Audiology
Speech Pathology
Counselling
Physiotherapy (WA, SA, TAS & NT)
Social Worker
Occupational Therapy
Exercise Physiology
Dietitics
Music Therapy
Podiatry
Art Therapy

Mean higher than price limit

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Mean, Median and 75th percentile billing rates

Comparing the NDIS price limits with the mean, median, and 75th percentile billing rates for therapy types reveals important insights into the alignment between NDIS price limits and market-driven billing practices.

Psychology

The relevant NDIS price limits for Psychologists are set at $214.41 for VIC, NSW, QLD, and ACT (state grouping 1), and $234.83 for WA, SA, TAS, and NT (state grouping 2). The statistical analysis shows that Psychologists have an average billing rate of $228.6, and Clinical Psychologists have a higher mean rate of $260.3. These amounts for this sample exceed the NDIS hourly price limits for Psychology supports, for both different state and territory groupings.

The median billings rates for Psychologists and Clinical Psychologists were at $228.0 and $255.0, respectively, which exceed the NDIS hourly price limits for Psychology supports, for most state and territory groupings.

The 75th percentile billing rates for psychologists and clinical psychologists are $254.2 and $284.4 respectively, indicating that a significant portion of billed appointments exceed the NDIS price limits.

This upper quartile of billing rates suggests that the private billing rates are frequently higher than the NDIS price limits. The benchmarking results indicate that the market rates for Psychology services, at the mean, medians and 75th percentile are now higher than the NDIS price limits.

Other therapy types

The following section discusses Audiology, Physiotherapy and Speech Pathology (selected due to sample being the next closest to the NDIS price limits). Note, $193.99 is the NDIS price limit for Audiology (national), Speech Pathology (national) and Physiotherapy (VIC, NSW, QLD, and ACT - state grouping 1). It is $224.62 for Physiotherapy in WA, SA, TAS, and NT (state grouping 2).

The means of private billing rates for Audiologists, Physiotherapy, and Speech Pathologists are $194.5, $202.7, and $192.7, respectively. For Physiotherapy, it has means of $197.0 and $220.9 for state groupings 1 and 2, respectively.

This is compared to the median billing rates for Audiology, Physiotherapy and Speech Pathology of $190.0, $200.0 and $193.3, respectively. For Physiotherapy, when considering the state groupings, the medians are $194.0 and $224.6 for state groupings 1 and 2, respectively.

At the 75th percentile, observed rates within the private market for these supports is $210.0 for Audiology, $240.0 for Physiotherapy, and $194.0 for Speech Pathology,

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Regressions

Regression analyses were undertaken to understand the relationship between therapy types, geographic regions, and billing rates, and to determine how these variables influence the price variability within the private therapy market. Table 22 details the results of the regression analysis. The dependent variable in all model regression models is the hourly private billing rate in dollars.

The analysis explores the similarities between some of the therapy groups. A series of Tukey’s range tests⁵¹ were undertaken to group therapy types with similar means of private billing rates. The test found that Audiology, Dietetics, Occupational Therapy, Physiotherapy, Speech Pathology, and Social Work share comparable billing averages (Group 1); while Art Therapy, Counselling, Exercise Physiology, Music Therapy, and Podiatry share similar means. Group 3 comprises of both Psychology and Clinical Psychology, which are distinct but are considered together for analytical simplicity. These grouping forms the basis of Model 3, which will be explained further below.

Table 22: Statistical Models of Private Billing Rates

⁵¹A Tukey range test is a statistical tool used to compare the means of different groups to determine if they are significantly different from each other, while accounting for the fact that multiple comparisons are being made.

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Variable	(1)	(2)	(3)
Constant	180.6***	178.1***	192.5***
Art Therapy	-25.5**	-23.3**
Audiology	13.1*	20.4*
Counselling	-30.6**	-32.7**
Dietetics	-0.7	-2.9
Exercise Physiology	-29.5***	-27.6***
Music Therapy	-14.8**	-20.1**
Physiotherapy	23.8***	20.4***
Podiatry	-22.7***	-21.5***
Psychology	47.1***	47.6***
Psychology — Clinical	90.1***	78.3***
Social Work	5.1	4.7
Speech Pathology	23.2***	22.4***
Counselling, Exercise Physiology, Art & Music Therapy & Podiatry			-40.2***
All Psychology			46.7***
Regional		-11.4***	-12.57***
NSW		23.2***	22.9***
QLD		2.8	0.2
SA		12.3**	11.5**
WA		0.2	-0.4
Tas		2.4**	3.5**
ACT		22.6**	19.1**
NT		53.7**	52.1**
Adjusted R²	0.321	0.352	0.315
F Statistic	70.76	51.2	92.01
Observations	1,791	1,791	1,791

(* = p <0.05, ** = p < 0.01, *** = p<0.001)

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Note: The baseline (Constant) for Model 1 is Occupational Therapy. The baseline in Model 2 is Occupational Therapy in Metropolitan Victoria and in Model 3 it is Group 1 therapies (Audiology, Dietetics, Occupational Therapy, Physiotherapy, Speech Pathology, and Social Work) in Metropolitan Victoria.

Regression results of three specifications are presented in this section. The modelling begins with each therapy type as variables, (Model 1). The base (or omitted) variable is Occupational Therapy, meaning the constant coefficient reflects the mean Occupational Therapy private billing fee. The coefficients attached to each therapy type reflects the fee relative to Occupational Therapy (for example, the coefficient attached to Art Therapy is -25.5 and hence the average billing rate for Art Therapy is $155.1 (180.6 minus 25.5)).

Model 2 builds upon Model 1 by including state/territory and regional indicators, with Occupational Therapy, Metropolitan and Victoria being the base variables that reflect the coefficient on the constant term. Model 3 keeps the geographical indicators but replaces the individual therapy variables with the groupings found using the Tukey difference in means tests discussed previously.

Model 2 is preferred over Models 1 and 3 for its slightly higher explanatory power, with an adjusted R-squared®*? of 0.352, indicating it explains 35.2% of the variations in private billing rates. The results suggest that the average hourly rate of $178 for Occupational Therapists in Metropolitan Victoria (Model 2), with Audiologists, Psychologists, Physiotherapists and Speech Pathologists appear to have exceeded the applicable NDIS price limits (statistically significant at 0.05 level).

A deep dive into the regression results revealed a meaningful statistical difference between both Clinical and Non-Clinical Psychology nation-wide. The results showed significant statistically difference consistent across applicable states and above its price limits. This adds significance to the previously discussed means, medians and 75

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The NDIA acknowledges that there are many uncaptured variables that would assist a greater explanation of private billing rates. This, however, is difficult to obtain through website scrapping alone.

Consultation feedback

The APR received 178 provider submissions, feedback from 13 professional bodies, one union, and 142 participants. A predominant theme was the suggested increase in the costs of delivering therapy support services, cited by approximately 87% of providers. These cost increases spanned across wages (including adjustments to meet Allied Health Awards and professional development), business expenses such as rent, utilities, office supplies, and insurance, as well as recruitment and retention challenges. The Ability Roundtable, incorporating an Allied Health Cost Model by Deloitte Access Economics, suggested a large difference, with a 12.9% variance between projected costs and the current NDIS Price Limit for major allied health disciplines. Professional bodies advocated for a price limit increase reflective of cumulative indexation since 2019 and suggested automatic indexation from 2025, claiming thin margins on which many small-scale therapy support businesses operate.

Regarding the provision of therapy and early childhood supports to both NDIS and non-NDIS participants, most providers catered to a mix of clients, with the proportion of NDIS participants ranging from 25% to nearly 100%. Despite the varied client base, appointment durations were often standardised, tailored to client needs rather than funding source, although complexities associated with NDIS participants sometimes necessitated longer sessions. Pricing approach varied, with most providers charging at the NDIS price limit, yet some reported differences in charges between NDIS and non-NDIS clients, attributed to the complexity of NDIS participants or additional administrative burdens. Unique costs associated with early childhood supports for NDIS participants were identified, including the need for team- based approaches, specialised skills, and extended appointments, which highlighted the complexity and intensity of services required. Professional bodies echoed these sentiments, emphasizing the need for specialised training and resources, particularly for providers catering to young children with disabilities.

See Appendix A for more details on common themes raised in submissions to the 2023-24 APR Consultation Paper.

Discussion

The Australian therapy market encompasses a wide array of services provided by allied health professionals, who are typically university-educated with specialised expertise in preventing, diagnosing, and treating various conditions and illnesses. While the NDIS forms an important part of this landscape, allied health services extend beyond NDIS funding. These services are also accessed through various other arrangements, including Medicare subsidies, private health insurance, where it

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is common for out-of-pocket payments to be made by the consumer, other government schemes, and the Department of Veterans Affairs (DVA).

In the 2022-23 financial year, 39% or approximately 10,389,000 individuals accessed allied health services**. For comparison 379,296 participants, representing 59% of the total 646,449 Scheme participants in the six months to 31 December 2023 accessed allied health supports using NDIS funding.

The NDIS therapy provider market has continued to demonstrate strong growth (14% growth for the six-month comparison to 31 December 2023 to same period the previous year), with a notable trend away from registered providers to a diversified unregistered provider market. The proxies the NDIA has used as an overview for market health and competition include the HHI, provider entry, periods of activity and inactivity and share of total NDIS therapy payments has suggested the market continues to mature and continues to meet increasing demand in most areas.

The NDIS therapy market operates in a manner that closely aligns with the characteristics of a deregulated, or private market, more so than other NDIS sub-markets. Despite its market-like behaviour, the NDIS therapy market includes regulatory mechanisms, specifically price limits, to assist participants receive value for money. These price limits are closely linked to the dynamics of the private market, ensuring that NDIS pricing remains competitive and reflective of current service costs.

Accordingly, other government schemes and the private billing market serve as suitable comparators to assess the appropriateness of the NDIS price limits. Feedback from consultations and discussions with various government funding schemes has indicated that, despite the relative smallness of users of the NDIS therapy market, it could act as a ‘price setter.’ Evidence of this may be seen in

53 Australian Institute of Health and Welfare (2022), Australia’s health 2022: in brief, catalogue number AUS 241. Australia’s health series number 18, AIHW, Australian Government.

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private billing rates, where the median and 75th percentile rates pricing for certain therapies align closely with the corresponding NDIS price limits.

Although benchmarking NDIS price limits against other comparable government funding schemes may introduce certain inaccuracies, it remains an important process. This ensures that government funding mechanisms do not inadvertently compete against each other for therapy professionals. Key factors to consider when comparing NDIS to other schemes include:

Risk assessment and pricing models: Some schemes often base pricing on risk assessments and pooled resources, which does not always reflect the costs of individualised support required by individuals, such as NDIS participants compared to the general population.
Contractual and volume discounts: Prices in other government schemes may be influenced by contractual agreements or volume discounts that are not applicable in the context of the NDIS service delivery that can lead to lower benchmarks.

The 2023-24 APR analysis of other schemes showed that while some have increased their pricing or funding levels, NDIS price limits remain consistent with the majority of therapies provided across these schemes. It is important to note, that there is significant variation in therapy pricing and funding levels among different schemes. Additionally, certain therapies such as Audiology, Art Therapy, and Music Therapy, which are covered by the NDIS, are not typically funded by other insurance schemes, including private health.

The analysis of private billing rates offers a comprehensive view of the diverse range of therapy supports available to NDIS participants, reflecting market-driven costs influenced by direct service delivery, provider expertise and current demand. By gathering a broad dataset of private billing rates from provider websites and adjusting them to effective hourly rates, the NDIA ensures a fair comparison across different therapies and geographic areas. This standardisation is important for assessing whether NDIS price limits align with market rates, thereby maintaining fairness and relevance within the private therapy sector.

The analysis indicates that NDIS price limits generally match or exceed the rates for most therapies nationwide. However, regression analysis highlights statistically significant variances among therapies, which could correspond to differences among therapy professionals such as in qualifications, skills, and experience.

Examining the statistically significant differences and general market pricing metrics, including the mean, median, and 75th percentiles, showed that rates for Psychologists often met or exceeded the NDIS price limits. Additionally, when compared with other government schemes, the NDIS price limits for Psychologists are not at the higher end of the spectrum. This information together suggests there is stronger evidence supporting adjustment to NDIS price limits for Psychologists compared to other types of therapists.

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Recommendations

Review of the current price limits for Psychologists against private billing rates and other comparable government schemes, it is apparent that the current limits generally sit below the prevailing market rates. The mean billing rate for psychologists is $228.6, with clinical psychologists at a higher rate of $260.3, both exceeding the NDIS hourly limits. The difference is further highlighted at the 75th percentile billing rates, where a significant portion of billed services are charged at higher rates than current price limits. This gap between market rates and the current NDIS price limits suggests that the NDIA should increase the hourly price limits, with the proposal being to use an indexation methodology of 80/20 split between the Australian Bureau of Statistics (ABS) Wage Price Index (WPI) and ABS Consumer Price Index (CPI).

Recommendation 4

The NDIA should increase the price limits for supports delivered by a Psychologist on 1 July 2024 in line with the weighted movement over the previous twelve months in the ABS Wage Price Index (Australia, total hourly rates of pay excluding bonuses) and the ABS Consumer Price Index (All Groups, weighted average of eight capital cities) over the 12 months to the March Quarter immediately preceding the indexation date (with an 80/20 weighting).

Specifically, this should be for support line items: ‘Assessment Recommendation Therapy or Training — Psychologist (15_054 0128 1_3), ‘Early Childhood Supports — Psychologist (15_001_0118 1 3)’, and ‘Specialist Behaviour Intervention Support (11_022_ 0110_7_3).’

Review of the alignment of the NDIS price limits for other therapists against the private billing rates and other comparable schemes suggests a general compatibility between NDIS price limits and prevailing market rates. In general, for most therapists, mean and median billing rates closely mirror the NDIS hourly price limits, which are set at $193.99 in most regions, suggesting that the current price limits adequately reflect market norms. Even when considering some therapists which means, medians and 75th percentile billing rates exceed NDIS price limits, the frequency of such instances does not indicate a systemic pricing concern that hinders participants from accessing these services relative to other clientele.

Recommendation 5

The NDIA should not make any further structural adjustments to the pricing arrangements for therapy supports at this time and should not index the price limits for all other therapy-related supports on 1 July 2024.

Support Coordination

Context

Support coordination, funded by the NDIS, is important for supporting participants to utilise their NDIS plans and achieve their goals. Support coordinators assist participants by connecting them to NDIS funded and mainstream supports, tailoring services and supports to individual participant wishes and plan budgets. They are also instrumental in enhancing participants’ abilities to understand and navigate the NDIS, empowering them to make informed decisions. This includes monitoring plan budgets and the effectiveness of supports, ensuring they align with participants’ needs, preferences, and goals.

To be effective in their roles, support coordinators need an in-depth understanding of the service offerings within a participant’s local market, identifying providers who can meet their needs and preferences. This often involves sourcing alternative providers to ensure continuity of support.

Registration is not mandatory for support coordinators. However, registered support coordination providers in groups: 0106: Assistance in coordinating or managing life stages, transitions, or supports, and 0132: Specialised Support Coordination must adhere to the NDIS Practice Standards. These standards cover participant rights, provider governance, and conflict of interest management.

The NDIS has an established pricing framework to cater to varying levels of support coordination, from basic Support Connection to Specialist Support Coordination for participants with higher support needs. This framework aims to provide a balanced pricing model, facilitating quality support for participants. The three levels — support connection (level 1), coordination of supports (level 2), and Specialist Support Coordination (level 3) — reflect the spectrum of assistance participants might require, each with designated price limits (Table 23). Additional information on the Price Limits and Pricing Arrangements for support coordination can be found on the NDIS website.

This chapter reviews the appropriateness of the current pricing arrangements for Support Coordination.

The NDIS Review

The final report from the Independent NDIS Review addressed foundational aspects of the current support system, making recommendations on the need to introduce a new navigation function. It acknowledges the essential role of support coordination in aiding participants to manage and implement their NDIS plans effectively but also suggests inconsistencies in its delivery and effectiveness.

Due to the proposed reforms recommended by the NDIS Review, developing a support coordination specific cost model at this point of time involves significant risk of having an outdated pricing model while the sector is undergoing significant evolution. On balance, it is not recommended for the NDIA to develop a specific cost model for Level 2: Coordination of Supports and Level 3: Specialist Support Coordination (Recommendation 9 from the 2022-23 Annual Pricing Review) now. A stable and predictable pricing framework over the transition period is important to allow participants and providers to plan with greater certainty and minimise disruption.

Scheme Statistics

Table 24 and Figure 36 show that in the six-month period to December 2023, 8,823 unique providers delivered support coordination to 245,696 participants, which accounts for 38% of all active participants in the Scheme. This activity represents $531 million in payments, or 3% of the total scheme spend. This is an 18% increase from the same period in the previous year, which saw $451 million in payments.

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Table 24: Summary of Changes in Support Coordination Participants, Total Providers and Total Claims

Statistics	July – December 2022	July – December 2023	Percentage Change
Total number of NDIS participants	215,817	245,696	+14%
Total number of active providers	6,802	8,823	+30%
Total amount claimed	$451 million	$531 million	+18%

Figure 36: Number of Participants and Providers Claiming Support Coordination Supports, January 2021 to December 2023

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

6.4 Participants

From July to December 2023, 230,621 participants used Level 2: Coordination of Supports. There were 10,354 participants who used Level 3: Specialist Support Coordination and 19,064 participants who used other support coordination supports (Level 1: Support Connection and Psychosocial Recovery Coach supports). Figure 37 illustrates the distribution of participants using different levels of support coordination compared to the previous year.

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Figure 37: Participants Using Different Levels of Support Coordination Supports

Support Coordination Level 3: Specialist

Support Coordination, 10,354
Other, 19,064 July- December 2023

Support Coordination Level 3: Specialist

Support Coordination, 8,446
Other, 14,214 July- December 2022

Source: NDIS internal administrative data

Providers

6.5.1 The number of providers continues to grow, especially unregistered providers

Figure 38 examines the growth of NDIS support coordination service providers between January 2021 and December 2023, showing differences in how fast different levels are expanding. The provider landscape has seen considerable growth, with the number of unique providers delivering Level 2 Support Coordination increasing from 3,445 to 7,799 over the period, an average six-month growth rate of 18%. The proportion of registered to unregistered providers has decreased from 79% to 42%, although registered providers still accounted for 82% of the total claims for these services in the six months to December 2023.

Notably, the number of providers for Level 2: Coordination of Supports has tripled over the observation period, showing a much faster growth rate compared to providers of Level 3: Specialist Support Coordination and other support coordination supports, which have grown at a slower pace.

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Figure 38: Number of Providers by Support Coordination Level, January 2021 to December 2023

Support Coordination Level	January - July 2021	June - December 2021	January - July 2022	June - December 2022	January - July 2023	June - December 2023
Level 1: Basic Support Coordination	8,000	7,799	6,897	7,000	6,006	6,000
Level 2: Coordination of Supports	4,565	1,345	1,154	5	744	875
Level 3: Specialist Support Coordination	1,867	2,000	2,491	2,000	2,136	—

Source: NDIS internal administrative data

Notes:

The table is incomplete and the last row for Level 3 has a missing value.
The last column in each row appears to be cut off or misaligned due to OCR issues.

6.5.2 The increasing number of unregistered providers has led to changes in market share

From January 2021 to December 2023, the market dynamics in the support coordination sector changed considerably. The period saw a 50% increase in the number of registered providers, alongside a four times increase in unregistered providers. During this time, the market share of unregistered providers grew from 75% to nearly 18%. Concurrently, the market share held by the top ten providers diminished from 121% to 7%, a trend observed consistently across different geographical settings; non-remote, remote and very remote areas (shown in Figure 40, Table 25 and Table 26). This decrease in concentration among the largest providers highlights the changing dynamics across the sector.

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	2021	2022	2023
10,000	8,823	8,000	Nae
11.0%	9.1%	9%	-
12%	6,802	4,905	6%
8.6%	4,000	3,818	3%
9%	2,000

	Non-Remote	Remote	Very Remote
60%	-	-	-
57%	-	-	-
50%	47%	40%	39%
40%	38%	40%	39%
30%	-	-	-
20%	-	-	-
10%	11%	9%	9%
9%	9%	8%	7%

Note: the chart shows market share for both registered and unregistered providers.

Source: NDIS internal administrative data

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Table 25: Registered Providers by Remoteness for Support Coordination Supports, January 2021 to December 2023

Remoteness	January – June 2021	July – December 2021	January – June 2022	July – December 2022	January – June 2023	July – December 2023
Non- remote	2,444	2,787	3,026	3,294	3,469	3,647
Remote	280	299	299	308	324	362
Very remote	168	182	175	187	199	212
Total for registered	2,467	2,810	3,044	3,332	3,503	3,686

Table 26: Unregistered Providers by Remoteness for Support Coordination Supports, January 2021 to December 2023

Remoteness	January – June 2021	July – December 2021	January – June 2022	July – December 2022	January – June 2023	July – December 2023
Non- remote	1,437	2,147	2,712	3,472	4,366	5,242
Remote	36	71	85	121	160	197
Very remote	23	35	47	69	80	98
Total for unregistered	1,455	2,174	2,739	3,518	4,420	5,300

Source: NDIS internal administrative data

Please note a discrepancy in the total number of ‘active’ therapy providers, attributable to two factors: firstly, some providers offer a mix of registered and unregistered supports, leading to their classification in both categories. Secondly, a small fraction of providers with undetermined registration status contributes to total payment figures but is excluded from detailed tabulation, representing less than 1% of the overall financial transactions.

There are a number of indicators which can be used to assess whether there is healthy competition in a market. While no single measure is a perfect indicator of the level of competition, the Herfindahl-Hirschman Index (HHI) measures market concentration and offers some insight into the health of the support coordination sector. A HHI under 1,500 indicates a market with many competitors and a lack of dominance by any single provider, which typically results in more choices. Conversely, a rise in the HHI indicates a rise in market concentration, suggesting less competition among providers.

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In the period from January 2021 to December 2023, the adjusted HHI for support coordination in metro areas has been low is currently at 16, indicating a less concentrated market. This is contrast by a much higher adjusted HHI in the remote (250) and very remote areas (371) which is consistent with a prior expectation (Figure 41). Moreover, the adjusted HHI for very remote areas has been decreasing until six months to December 2022. Since then, the adjusted HHI for very remote areas has increased again but not back to the levels two to three years ago.

Figure 41: Herfindahl-Hirschman Index for Support Coordination Supports, January 2021 to December 2023

Market concentration
More
Remote
January - June 2021
450

Source: NDIS internal administrative data

The unregistered support coordination market appears to be structured differently

Submissions to the APR from registered support coordinators and peak bodies suggest differences in cost structures between registered and unregistered providers. It is claimed that registered providers face additional financial imposts stemming from the registration process and ongoing compliance obligations, expenses not shared by their unregistered counterparts. This difference in operational costs potentially influences pricing strategies, where registered providers may price their services at or near the NDIS price limit to offset costs associated with regulatory compliance.

Figure 42 and Figure 43 show the distribution of support coordination providers by registration and entity type for the six months to December 31, 2023. Figure 42 shows that registered providers are mostly companies providing significant NDIS

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supports, while Figure 43 shows that unregistered providers are mostly sole traders especially those with lower turnover.

Registered providers claimed 82% of the support coordination payments made to all providers. This demonstrates that registered providers, although representing a smaller proportion of the total providers count (5,300 unregistered providers to 3,686 registered providers), are responsible for the majority of payments in terms of service delivery.

Figure 42: Registered Providers of Support Coordination Supports by Entity Type and Total Payments, July to December 2023

	Less than $50k	$50k < $250k	$250 < $500k	$500 < $1m	$1m +
Sole Trader	387	496	255	255	255
Partnership	10	10	10	10	10
Company	10	10	10	10	10
Trust/Govt/Fund	387	496	255	255	255

Source: NDIS internal administrative data

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Figure 43: Unregistered Providers of Support Coordination Supports by Entity Type and Total Payments, July to December 2023

Less than $50k	$50k < $250k	$250 < $500k	$500 < $1m	$1m +
Sole Trader	Partnership	Company	Trust/Govt/Fund

Source: NDIS internal administrative data

These above figures highlight a contrast in the type of markets across unregistered and registered support coordinators. That is, the make-up of markets, payment-wise, the unregistered support coordinator market seems to be dominated by smaller sole traders, compared to the registered support coordinator market that is predominantly larger companies.

Table 27 shows that approximately 13% of support coordination services were delivered at rates below the NDIS price limits. This trend has been driven by activities of unregistered providers, who are more likely to claim below the price limits. Unregistered providers have seen their share of total transactions increase from 2% in the six-month period from January to June 2021 to 12% in the six-month period from July to December 2023, underscoring their growing presence and competitive pricing strategies within the NDIS market.

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Table 27: Claiming Patterns at Price Limit Analysis for Support Coordination Supports, January 2021 to December 2023

Claiming patterns — At price limit	Janu ary – June 2021	July – Decemb er 2021	Janu ary – June 2022	July – Decemb er 2022	Janu ary – June 2023	July – Decemb er 2023
Registered	91%	93%	93%	92%	90%	89%
Unregistered	66%	72%	75%	74%	74%	72%
All Providers	91%	92%	92%	91%	89%	87%

Source: NDIS internal administrative data

Note: All Providers above are inclusive of providers with the unknown registration status at the time of the transaction.

Business dynamism in the NDIS support coordination market

This section examines the vitality and changes within the market for support coordination of registered providers. The analysis in this section focuses on registered providers as it reflects the majority of the payments (82% in the six months leading to December 2023). Business dynamism refers to the rate at which new providers enter the market and existing providers exit. This is one of many indicators of the market’s health, competitiveness, and its capacity to innovate and meet participants needs.

54 Data analysis of registered provider payment activity by the NDIA includes payments made against Agency managed plans, which are attributed to registered providers, and payments for plan management services. Providers with an unclear status at the time of transaction or those providing an invalid ABN have been excluded from this analysis.

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Comparison of provider payments for “new” activity and inactivity

To further assess the market dynamics, the NDIA reviewed the payment activities of registered providers over a three-year period from January 2021 to December 2023. ‘New activity’ is characterised by providers receiving payments in the half-year who did not receive payments in the preceding half-year. Conversely, ‘inactivity’ refers to providers not receiving payments in a half-year after having received payments in the previous one. Each provider’s activity is quantified as a percentage of the total payments within that half-year for new activity, of the prior half-year for inactivity. The NDIA recognises that this method does not perfectly measure market exits but provides the best estimation with the data available.

The data indicate that over the three years, providers who became inactive in any half-year accounted for 0.4% to 0.6% of the total payments. On the other hand, providers with new activity in any half-year contributed to 1.1% to 2.2% of the total payments.

Figure 44 displays the change in registered provider activity between January 2021 to December 2023. Payments made to “new” active providers are consistently higher than payments made to providers in the six-month period before they became inactive.

Figure 44: Registered Support Coordination Provider Activity Movements, January 2021 to December 2023

	New Activity as Percent of Total Half-Year Payments	Inactivity as Percent of Prior Total Half-Year Payments
January - June 2021	1.6%	0.5%
July - December 2021	2.2%	0.4%
January - June 2022	1.2%	0.6%
July - December 2022	1.5%	0.5%
January - June 2023	1.1%	0.5%
July - December 2023	1.8%	0.6%

Source: NDIS internal administrative data

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The number of providers continues to grow, driven by unregistered providers

Figure 45 illustrates a comparison of new support coordination provider volumes by registration type from January to July 2021 to July to December 2023. It shows a consistent trend where the growth of new unregistered providers outpaces that of registered ones throughout the observed period.

Figure 45: New Support Coordination Provider Counts, January 2021 to December 2023

	Registered	Unregistered
January - June 2021	473	919
July - December 2021	460	1,096
January - June 2022	378	1,136
July - December 2022	429	1,376
January - June 2023	346	1,634
July - December 2023	366	1,815

Source: NDIS internal administrative data

Registered providers show more payment stability than unregistered providers

Assessing the stability of support coordination providers there is a pronounced distinction between the registered and unregistered provider market. Figure 46 shows the number of half years with payments, with providers split up by registration status. It also shows the percentage of total support coordination payments for each grouping as a portion of total registered and unregistered payments combined. This figure shows that approximately 38% of registered providers have consistently been active across the last six half-year periods, receiving 78.3% of total payments in the six months to December 2023, indicating a high degree of payment stability. Conversely, only about 6% of unregistered providers have maintained the same level of payment activity, accounting for 3.3% of total payments.

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Figure 46: Provider Continuity by Registration Status and Percentage of Total Payments. Registered Providers (Left) and Unregistered Providers (Right), January 2021 to December 2023

Number of Half Years with Payment	Number of Providers	Percentage of Total Payments
1	redacted: s47 - irrelevant material	redacted: s47 - irrelevant material
2	redacted: s47 - irrelevant material	redacted: s47 - irrelevant material
3	redacted: s47 - irrelevant material	redacted: s47 - irrelevant material
4	redacted: s47 - irrelevant material	redacted: s47 - irrelevant material
5	redacted: s47 - irrelevant material	redacted: s47 - irrelevant material
6	redacted: s47 - irrelevant material	redacted: s47 - irrelevant material

Providers with uninterrupted payment history support more participants

A distribution analysis (Figure 47) categorises providers by the number of participants they support, and the proportion of services claimed. Over the timeframe from January 2021 to December 2023, segmented into six-month intervals, the profile of registered providers has remained consistent, suggesting a stability in the scale at which providers operate. In the six months leading to December 2023, 15% (558) of active registered providers were supporting a single participant. Meanwhile, 46% (1,702) of active registered providers were servicing more than 20 participants, contributing to 94% of the total payments to registered support coordination providers within this period.

Figure 47: Registered Providers of Support Coordination Supports and Number of Participants Claimed from, January 2021 to December 2023

Number of Participants	Number of Providers (January - June 2021)	Percentage of Total Payments (January - June 2021)	Number of Providers (July - December 2023)	Percentage of Total Payments (July - December 2023)
1 Participant	310	0.2%	redacted: s47 - irrelevant material	redacted: s47 - irrelevant material
2-5 Participants	405	0.6%	646	0.9%
6-10 Participants	222	0.9%	355	1.2%
11-20 Participants	297	2.5%	425	2.9%
More than 20 Participants	1,233	95.8%	1,702	94.8%

6.7 Disability Intermediaries Australia Benchmarking Survey

Disability Intermediaries Australia (DIA) submitted a benchmarking survey to the Annual Pricing Review (APR), gathering data from 1,386 intermediary service providers, including both Plan Managers and Support Coordination providers, categorised as registered and unregistered. Among these, 865 submissions were from support coordination providers, with 91% identified as for-profit organisations and the remainder as not-for-profit. It was noted a 24% increase in smaller providers participating in the survey compared to the previous year.

The benchmarking survey highlights concerns regarding static NDIS price limits since July 1, 2020, which have reportedly led some providers to cease operations or deregister, primarily affecting Level 2 and Level 3 support coordination. Despite these challenges, the broader data presented in the report indicates a substantial and continuous growth in the support coordination market. From 2021 to 2023, the number of providers significantly increased from 2,637 to 8,823.

Regarding employment conditions, most staff, including those interacting directly with participants and their supervisors, are reported to be compensated according to the SCHADS Award, covering 92% and 91% of the workforce, respectively. The survey reported a 10% increase in losses and a 24% decrease in profits from the previous year among providers. It documented mean operational overhead costs per hour at $19.34 for Level 1, $38.17 for Level 2, and $90.70 for Level 3 support coordination. This is suggested to 37.2%, 55.3% and 93.3% for Support Coordination Level 1, Level 2, and Level 3, respectively (operational overheads divided by cumulative cost per hour before operational overheads).

The survey also reported other additional employment-related expenses include a 17.5% annual leave loading, accrual of 76 hours of personal leave annually, and an increase in the superannuation guarantee from 10.5% to 11% for the 2023-24 financial year. The survey indicated that the diversity in organisational structures

Provider Consultation Feedback

The NDIA received 55 submissions from providers responding to the consultation questions regarding support coordination. Approximately 75% of submissions indicated significant changes in service delivery costs over the past year. Submissions highlight a discrepancy between rising operational expenses—such as audit costs, wages, rent, and fuel—and the static NDIS price limits for support coordination. Providers emphasise the financial strain from increased audit expenses and operational costs without corresponding price adjustments.

Concerns over sustainability and the viability of services underscore the discussions, with fears that the quality and diversity of support coordination services may dwindle, potentially undermining the NDIS’ goal of ensuring participant choice and control. Additionally, providers report a marked increase in the effort required to navigate NDIA regulatory processes. This, coupled with funding inadequacies and workforce instability, including high turnover and the added stress of billable Key Performance Indicators (KPIs), compounds the operational difficulties facing the sector.

Participant Consultation Feedback

Feedback from NDIS participants on their experiences with support coordination services reveals a wide spectrum of satisfaction. According to a survey, 63% of participants expressed satisfaction, appreciating their coordinators for effectively connecting them with suitable providers and enhancing their access to necessary services. These participants valued the coordinators’ ability to navigate the complexities of NDIS services. However, 22% of participants reported dissatisfaction, attributing their discontent to the high costs, frequent changes in coordinators, and a lack of responsiveness, which sometimes led them to consider changing providers.

Discussion

This chapter has explored the growth and evolving landscape of the support coordination market from July to December 2023, marked by a significant increase in both the number of providers and participants utilising support coordination services. Notably, the market has seen a substantial rise in unregistered providers, growing from 2,637 to 8,823 over the past three years. Despite this influx of new entrants, registered providers still accounted for 82% of total claims, highlighting their important role in the ecosystem even as the number of registered providers has declined.

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The market is undergoing a transformation towards less concentration, evidenced by unregistered providers gaining a greater market share and the top ten providers experiencing a reduction. This shift is further supported by data from the HHI, indicating a decrease in market concentration.

Provider submissions and participant feedback underscore the rising costs of service delivery and the challenges in maintaining service quality under the current financial model. Such feedback highlights the complex interplay between cost management and service quality, particularly for Level 2: Coordination of Supports and Level 3: Specialist Support Coordination. These levels are crucial for detailed planning, case management, and crisis resolution, requiring providers to possess extensive knowledge and the ability to integrate supports across various sectors.

Recommendations

It is considered reasonable that support coordination supports currently determined by the Disability Support Worker (DSW) Cost Model, continue to be done so, including any applicable changes that occurs for DSW supports.

Recommendation 6

The NDIA should index the price limits for Level 1: Support Connection services and Psychosocial Recovery Coaches services in line with the indexation of supports determined by the Disability Support Worker Cost Model in recommendation 1 on 1 July 2024.

Analyses in the chapter highlights that whilst the market for support coordination continues to evolve, there is no evidence to suggest that supply is not meeting demand. In light of significant upcoming reforms recommended by the NDIS Review, which aim to enhance service integration and improve participant outcomes, there is a strong rationale to mitigate potential market disruptions during this transformative period. Any changes to pricing at this point of time would be up for further changes until the reforms in the intermediary sector settle. On balance, it is not recommended to change the price limits of Level 2 and Level 3 support coordinators to ease undue disruption.

Recommendation 7

In alignment with strategic outcomes from the NDIS Review and recognising the current period of significant reform, it is recommended that the NDIA maintain existing price limits for Level 2: Coordination of Supports and Level 3: Specialist Support Coordination.

Short Notice Cancellation Policy

Context

The NDIS short-notice cancellation policy intends to allow providers to recover costs faced from participant cancellations where costs are incurred within a reasonable timeframe. The existing policy, while designed to ensure providers meet their legal obligations to workers without financial detriment, may not fully reflect the varied and fluid operational landscapes in which these services are delivered.

In July 2022, the NDIA updated its short notice cancellation policy from 2 days to 7 days, for applicable NDIS supports, in line with the Social, Community, Homecare and Disability Services Industry Award 2010 (SCHADS Award). The policy allows service providers to claim up to 100% of the agreed fee for a scheduled appointment if it is cancelled on short notice. Short notice is defined in two main scenarios: if the participant does not show up within a reasonable time for the scheduled support, or if the participant cancels with less than 7 days’ notice. Furthermore, for supports intended for a group, if a participant cancels and cannot be replaced, the provider may bill for the cancelled attendance at the agreed rate.

Providers can claim for these cancellations directly from the participant’s plan, provided several conditions are met. These include:

The support item being eligible for short notice cancellation claims as per the NDIS Pricing Arrangements and Price Limits,
The charges comply with these pricing arrangements and limits,
There is a pre-existing agreement with the participant allowing for such claims; and
The provider was unable to find alternative billable work for the staff involved.

Claims for short notice cancellations must be submitted using the ‘cancellation’ option in the NDIS Myplace portal, using the same support item used for the actual service delivery.

7.1.1 The short notice cancellation policy aligns with the SCHADS Award

The NDIS short-notice cancellation policy aims to balance the costs incurred by service providers with value for money for participants. It recognises the financial and operational impacts of cancellations on providers, ensuring they can recover costs when services are cancelled without sufficient notice. The policy encourages participants to give timely cancellation notice, allowing for providers to effectively manage their resources.

Additionally, the policy aims to safeguard participants’ flexible needs by setting clear expectations around cancellations. By establishing a fair and transparent framework, it fosters a cooperative relationship between participants and providers.

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includes provisions for monitoring and addressing frequent cancellations, emphasising the provider’s duty of care.

The Fair Work Commission (FWC) updated the client cancellation requirements for workers under the SCHADS Award starting 1 July 2022. Clause 25.5(f)(v-vi) requires employers to handle client cancellations within seven days of the scheduled date, applying only to employees covered by the SCHADS Award. Employers can either reassign employees to other tasks or cancel the shift entirely.

When a client cancels, employers must compensate employees for the scheduled hours or arrange make-up time, provided the employee was notified at least 12 hours before their shift. Make-up time should be arranged within six weeks of the cancellation, in consultation with the employee, potentially involving work in other business areas. This provision is designed to be flexible for both employers and employees, ensuring fair compensation while adjusting work schedules.

In practice, providers often rearrange worker shifts under the SCHADS Award, even with less than seven days’ notice. This flexibility helps reduce the financial consequences of client-initiated cancellations. However, there can still be additional costs for make-up shifts, especially if the shift changes from daytime to evening/weekend work, potentially leading to financial loss.

The current NDIS short-notice cancellation policy also applies to supports not delivered by DSWs under the SCHADS Award, even though they do not have the same legislative requirements.

No legislative requirements exist for similar sectors under the Aged Care Award 2010 and Children Services Award 2010. For therapy providers, the Health Professionals and Support Services Award 2020 doesn’t include requirements for client cancellations. This serves as the minimum award for many types of therapists delivering NDIS supports.

— ndis.gov.au 2023-24 Annual Pricing Review —

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Scheme Statistics

7.2.1 The number of short notice cancellations claims has grown

Since the revision of the NDIS short notice cancellation policy from July 2022, there has been a significant increase in the number of claims and corresponding Scheme expenditure associated with short notice cancellations. From the financial year 2020-21 to 2022-23, Scheme expenditure has nearly doubled (97%), from around $60 million to just under $120 million. Figure 48 shows this increase on a half yearly basis, comparing the total expenditure on cancellation claims against the overall expenditure for all supports delivered by registered providers.

Figure 48: Scheme Expenditure of Cancellation Claims Compared to Total Scheme Expenditure from July 2020 to December 2023


$80 m	0.40%	$60 m	0.30%
$40 m	0.20%
$0 m	0.00%

July - January - July - January - July - January - July - December June December June December June December 2020 2021 2021 2022 2022 2023 2023

Cancellation Claims ($) Source: NDIS internal administrative data ——Cancellation as a Percentage (%) of Total Claims

The NDIA also analysed Scheme data by Modified Monash Model areas (MMM) that revealed no significant difference in cancellation rates between metropolitan and remote/very remote locations. This finding suggests that geographical factors may not be major determinants of cancellations, and thus does not warrant a policy consideration focused on location.

Therapeutic supports account for more than one third of all cancellation claims Figure 49 breaks down the cancellation claims by the top 4 registration groups, with ‘0128: Therapeutic Supports’ and ‘0118: Early Childhood Supports’ together accounting for 37% of the total in the six months to December 2023. These two registration groups, generally with workers not covered by the SCHADS Award,

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contrast with other registration groups such as ‘0136: Group and Centre Based Activities’ and ‘0125: Participant in the Community, Social and Civic Activities’. The latter comprises 31% of cancellation claims and have workers under the SCHADS Award requirements.

Other supports spread across fifteen other registration groups represent 32% of claims, indicating cancellations are common across various NDIS services. Frequency of cancellation claims of other registration groups are also rising over the observed period at a less rapid rate.

Figure 49: Trend in Cancellation Claims by Top 4 Registration Groups from July 2020 to December 2023

	Group/Centre Activities (0136)	Early Childhood Supports (0118)	Participate Community (0125)	Therapeutic Supports (0128)
July - December 2020	$4 m	$4 m	$3.5 m	$3.5 m
January - June 2021	$5 m	$9 m	$6 m	$8 m
July - December 2021	$5 m	$10 m	$7 m	$9 m
January - June 2022	$6 m	$14 m	$8.5 m	$11 m
July - December 2022	$7 m	$15 m	$10 m	$13 m
January - June 2023	$6 m	$12 m	$9 m	$14 m
July - December 2023	$8 m	$16 m	$14 m	$15 m

Source: NDIS internal administrative data

Consultation Feedback

7.3.1 The lack of unity in cancellation policies

Since the NDIA revised the short notice cancellation policy, participants and stakeholders have shared feedback through ministerial correspondence and the public APR consultation. They emphasised the wide variety of cancellation policies used by NDIS providers. Participants highlighted varying levels of understanding regarding these policies, with some discovering the provider’s rules after being charged for the cancelled appointment. According to participant consultation responses, 78% of participants knew their provider had a cancellation policy, and 45% noted different rules applied to different services. This diversity illustrates the complexity of the marketplace.

Among providers who responded to the consultation, the majority delivering DSW supports (52%) and support coordination (53%) followed the seven-day cancellation

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policy. In contrast, 76% of therapy providers reported following a policy of less than 48 hours (Figure 50). One provider explained:

“We follow a seven-day policy for DSW services, but therapy services are cancelled within 48 hours due to their nature”

Figure 50: Provider Submission Responses to Short Notice Cancellation Policies


7 days	72 hours	48 hours
24 hours	9am day prior	2:30pm the day prior
2 hours

Number of Responses Source: NDIS internal administrative data

One provider noted the difference in how cancellation policies are applied between NDIS and non-NDIS participants. This is discussed further in section 4 of this chapter.

“This is different to non-NDIS participants and | will explain why. We are unable to charge for cancellations under HCP, workcover or DVA so don’t charge those clients. Our private clients we can charge up to 100% of the appointment cost if they fail to attend or cancel late notice if there is not a reasonable explanation for the failure to attend.

Discrepancies and confusion

Providers noted discrepancies in the interpretation of cancellation policies, leading to canfusion and frustration among participants. One provider shared:

“Clients often don’t realise the financial impact their late cancellation has on our operations”

The lack of understanding often results from insufficient education on cancellation fees and participant awareness of the policy’s effects. Strictness in policy enforcement further contributes to the perception of unfairness. Some participants

Mitigation strategies

Providers have highlighted various strategies to minimise the impact of short notice cancellations on NDIS participants. These include flexible appointment rescheduling, sliding scale fees, and telehealth services. One provider explained:

“As an alternative to a short notice cancellation, we offer telehealth appointments, or offer non-face to face services (if required) such as resource development or report writing. If these strategies are accepted, the cancellation charge is not applied…. We support Participants to achieve attendance at their appointments by providing SMS and/or phone call and/or email reminders, and implement various appointment scheduling strategies (for example, scheduling consistent times to reduce change).”

Another provider suggested sending appointment reminders 48 hours before to allow participants to adjust their schedules or cancel with enough notice:

“We send reminder text messages, we work with scheduling to ensure we are able to provide flexible appointment times that suit the participant needs.”

These strategies reflect a shift toward flexible service models designed to maintain continuity and adapt to participant’s evolving needs.

Flexibility and tailored engagement

Providers emphasised the importance of tailoring engagement with participants to prevent cancellations. For instance, a psychology provider emphasised the need for effective communication with care managers or house managers in cases of frequent cancellations to understand underlying issues:

“We tailor our approach to each individual participant based on their living or travelling circumstances. In instances of frequent cancellations, we typically engage in communication with the care manager or house manager to address the situation effectively.” Similarly, an Occupational Therapy provider highlighted the role of reminders and personalised communication through text, phone, or email:

“We have multiple reminders automated on software via email and SMS. A peak body highlighted the most common approaches for their members:

“Telehealth is the most mentioned alternative to short notice cancellations; other alternatives include home exercise programs. Some respondents also mention using the time allocated for cancelled appointments for billable non —face-to-face supports such as administrative tasks or report writing, assistive technology trials, liaison with care team, updating a home program, etc.”

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These personalised approaches help identify and overcome barriers to attendance, keeping services flexible and participant centred.

Understanding reasons for cancellations

Short notice cancellations occur for various reasons, including logistical challenges and sudden illness. Participant feedback revealed frustration with some notice periods, as many find it unreasonable to predict their availability seven days in advance. One participant shared:

“For Physiotherapy, it is 7 working days or full price is charged. (Honestly, how do you know 7 days out if you are going to be sick?)”

Participants often cancel appointments due to unpredictable factors like illness, hospitalisations, or caring for sick children, calling for policies that balance predictability with fairness. They expressed the need for more empathetic practices, particularly for emergencies. Some providers understood this and showed flexibility:

“My solo provider doesn’t charge for cancellations due to sickness or emergencies even if I let her know that morning. She requires 48 hrs notice for cancellation if it’s due to change of plan or something I know about beforehand.”

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“Can be anywhere from 2 weeks to 24 hrs and has to be in writing which is not good for some.” This inconsistency makes it difficult for those managing complex situations, who may need to cancel due to sudden illness or emergencies. Participants often find themselves penalised for cancelling on short notice.

Rules also differ depending on the reason for cancellation. Planned absences like holidays or medical appointments and unplanned absences like illness are treated with distinct rules, which many consider arbitrary or unfair. One participant noted:

“Different rules for planned reasons to miss a session (eg holiday, medical appointment, etc) versus if | am sick (which has a much shorter notice period).” Discrepancies between participant and provider cancellations exacerbate the confusion. One participant expressed concern:

“With current services, if | cancel the service less than 48 hours before the support worker is due, | pay the full amount, but if they cancel or don’t show up, that is supposed to be ok.” Some participants feel unable to seek clarification or negotiate their terms of support, citing a lack of transparency and flexibility from providers. One participant said:

“Eight hours for OT and psychologist. The OT only requires 24 hours for private patients and has not responded to my email enquiry questioning the reason for the difference for participants.” Participants believe that short notice cancellation policies should account for their circumstances, ensuring they’re not penalised unfairly. Improving communication and transparency would help alleviate confusion and frustration.

Discussion

Analyses on NDIA-related short-notice cancellation claims does have its limitations. While some insights can be observed from NDIS cancellation claim data, there are limitations that prevent a comprehensive deep dive. These are:

Notice period: The NDIA system does not currently capture the advanced notice period provided by a participant for cancellation claims (i.e., one day before or 5 days before).
Limited reasons: The NDIA system prompts providers to select a cancellation reason from a list though this is not an exhaustive list of potential reasons. However, a significant portion of cancellations claims (70%) are classified as “Not Defined” or “Other”. This lack of specificity makes it difficult to understand the true driver behind most cancellation claims in the NDIS.

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No free-text field: The system does not offer a free-text field for providers to explain cancellation reasons beyond the predefined options.

Due to the lack of current NDIS administrative data for analysis, it is more reasonable to consider analysis of the marketplace and current practices for this policy.

7.4.1 Market analysis and efficiencies

This section examines cancellation policies across various government schemes in Australia, focusing on their similarities and differences with the NDIS.

Aged Care: A mature market with different practices

The most comparable sector for DSW supports is Aged Care, specifically the Home Care Package program within Aged Care. Home Care providers must be registered with the Australian Aged Care Quality and Safety Commission®° and can charge additional fees beyond hourly rates, such as care management and package management fees*®.

Thus, providers delivering this program have more flexibility in setting prices, allowing them to potentially absorb some costs associated with cancellations. This is reflected in a sampling of Home Care Package providers cancellation policies, acknowledging this sample is not representative of the entire aged care sector. From a sample of 50 randomly selected Home Care Package providers that listed clear cancellation policies, 96% (48 providers) did not charge for cancellations if given more than 2 business days’ notice (Table 28). Most providers charged the full fee if the cancellation was within the notice period.

55 Homepage | Aged Care Quality and Safety Commission 56 Provider Guidance - Home Services Pricing and Agreements | Aged Care Quality and Safety Commission

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Table 28: Review of 50 Aged Care Providers Delivering Home Care Package Supports Cancellation Notice Periods

Required Notice to avoid cancellation charges	24 Hours or Day Prior	2 business days or less	More than 2 business days
Number of providers with this policy	41	7	2
Percentage of providers	82%	14%	4%

Other Government Funding Schemes

Table 29 compares cancellation policies against other government schemes, such as Medicare and Department of Veterans Affairs (DVA). Many other Government Schemes offer limited or no ability for providers to claim for cancellations. While some, like Medicare allow participant charges for non-attendance, this approach may not be feasible for NDIS participants due to the NDIS required to cover the reasonable and necessary support needs of participants and considering reasonable costs associated with service delivery.

However, it is important to note that unlike the NDIS, these schemes generally do not prohibit providers from charging cancellation fees directly to participants.

Table 29: Comparison of Other Comparable Government Funding Schemes and their Cancellation Policies

Scheme	Cancellations
Medicare	Not covered
DVA	Not covered
Transport Accident Commission (TAC)	Not covered unless fee schedule has specific items
ComCare	Not covered (except for Medical Practitioners)
Return To Work South Australia (RTWSA)	Not covered (except for Medical Practitioners)
Victims of Crime Assistance Tribunal (VOCAT)	Not covered for no-shows by clients
Worksafe Vic	Not covered (except for Medical Practitioners)
WorkCover Qld	Not covered (except for Medical Practitioners)

As part of the APR’s Therapy Analysis, the NDIA received responses from 13 Commonwealth and State Schemes on their therapy pricing and arrangements such

Market Cancellation Data through Website Scrapping

Following consultation feedback that suggested there was a segment of participants that were not aware of their provider’s cancellation policy, the NDIA conducted a website analysis of 300 NDIS providers who claimed for a cancellation in Financial Year 2022-23. These providers were randomly selected from 1,700 NDIS providers who made over $10,000 worth of claims for short-notice cancellation in 2022-23. Noting the NDIA does not mandate providers to publicly display their cancellation policies.

Findings from this sample of providers suggested a potential lack of transparency:

Only 16% of providers had a clear cancellation policy directly accessible on their website. This means 84% had no explicit mention of their cancellation policy.
12% offered downloadable terms and conditions, where only some included a clear cancellation clause.

Among the 49 providers with published policies:

80% did not claim up to the 7-day notice period, the majority of whom offered a 48-hour notice period.
16% had a 7-day cancellation policy.
4% differentiated policies between private clients and NDIS participants.

These findings suggest from the sample with published cancellation policies, there are many providers who offer a shorter notice period (48 hours) than the maximum allowable 7-day period. This supports a market that could potentially sustain a shorter notice period than the current NDIS short notice cancellation policy.

From this exercise, the NDIA consider there is a need for potential improved transparency regarding cancellation policies within the NDIS system. There is evidence from submissions to the APR that participants are only made aware of a provider’s cancellation policy after the fact. There is a need for clear cancellation policy that is not only balancing the needs of participants and costs of providers, but that is also communicated between both parties.

Use of Diverse Models and Technology

The NDIA operates in a diverse environment with a huge range of providers in terms of size, support coverage, access to technology, and levels of efficiency.

Mitigation strategies

APR consultation respondents suggested mitigation strategies like reminder messages, telehealth options, and reallocating staff to other work or training. There is general support amongst providers of the efficacy of reminders (via SMS, phone, etc.) in reducing no-shows, although no single method consistently outperforms others. These approaches could limit the need to claim for cancellations, with providers using innovative practices to maximise support time.

Understanding reasons for cancellations

Non-attendance reasons vary from transport issues and childcare needs to opportunity costs like time and money. Lead time between bookings is a good predictor of no-shows, and prior history often indicates future cancellations. However, situations like sudden illness may necessitate a more flexible cancellation policy to accommodate participants’ diverse and unpredictable needs.

Recommendations

The NDIA operates within a diverse landscape of providers varying in size, support coverage, technological access, and efficiency. This diversity significantly influences cancellation policy applications, scheduling, and rostering systems.

In therapeutic and nursing supports, a worker may assist multiple participants per shift, meaning that the cancellation of one appointment won’t usually lead to a cancelled shift. However, for longer-duration supports like Supported Independent Living (SIL), the rostered shift might align more closely with scheduled support.

The NDIA acknowledges that providers have the right to recoup costs from cancellations affecting their operations, but emphasises the need for fairness to participants, providers, and taxpayers. While the current cancellation policy applied to all NDIS supports, it deviates from the original intent of the SCHADS Award (which covers the cost of a support worker’s shift) and differs from the private therapy market (typically operating with 24 to 48-hour notice periods).

Consultations with stakeholders, including service providers, participants, and peak bodies, revealed a clear demand for a short-notice cancellation policy adaptable enough to reflect the realities of service delivery while ensuring participants continue to receive the supports they need.

The NDIA recognises that there is a need to strike a balance in its short-notice cancellation policy to allow providers sufficient ability to recover costs while incentivising them to work with participants to reduce the number of short-notice cancellations. Participants, in turn, must be given reasonable period to provide

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notice, considering unforeseen circumstances like illness, urgent appointments, or changes in personal circumstances, to minimise using NDIS funds on service they don’t receive.

Providers delivering DSW-related supports can incur costs if they cannot redeploy employees to other work or set up make-up shifts for the staff, as these employees are generally covered by the SCHADS Award. This requirement is unique to the care sector for workers under the SCHADS Award.

The NDIA believes that NDIS providers should generally be able to reschedule staff according to the SCHADS Award to minimise claims for cancellations from NDIS participants, thought this might not be feasible in all situations (e.g. SIL supports). Providers who reschedule or find alternative work for their employees should not claim short-notice cancellation fees from the affected participant, as alternative arrangements have been made for the worker.

On balance, the NDIA recognises the diversity of operational contexts in which providers operate, which includes potential costs that could be faced by providers to meet legislative requirements to their workers in instances beyond their control. It is important that the cancellation policy incentivises providers to minimise the cost of cancellations, while also signalling to participants that they should provide as much notice as possible when cancelling their services and supports. This recognition forms the basis for the recommendations aimed at refining the NDIS cancellation policy to better align with Service Delivery.

Recommendation 8

The NDIA should retain the existing 7-day short notice cancellation policy for applicable supports determined by or derived from the Disability Support Worker Cost Model from 1 July 2024. Providers of Disability Support Worker supports must continue to make reasonable effort to find alternative billable work for the staff involved.

For non-DSW related supports (non-SCHADS related), such as therapy services, lack a standardised legislative or Award requirement for client cancellations. This is the case for other comparable care and support services such as Aged Care and Children’s Services. There is also limited cancellation policies in other Government funding schemes.

Through consultation and research conducted, there is a case that the maximum of 7-day policy may not be necessary for non-DSW supports. There appears to be a greater usage of a 2-day cancellation policy in the sector, particularly among therapy providers, which supports a potential for a shorter cancellation policy. 76% of provider respondents delivering therapy supports to NDIS participants suggest they already have a short-notice cancellation policy of 48 hours or less. This is also supported by the website data analysis conducted by the NDIA, acknowledging the

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limited sample that had available data for analysis. The NDIA believes there to be mechanisms and methods already being utilised by the sector to assist participants limiting cancellations which could make the reduction in notice period feasible.

Recommendation 9

The NDIA should adjust the 7-day short-notice cancellation policy for non-Disability Support Worker-related supports to two clear business days from 1 July 2024.

Feedback from the Participant Consultation Paper

Context

The 2023-24 APR has an increased focus on participants to ensure that it includes the voices of both providers and participants. For the first time, the NDIA published a dedicated consultation paper to gather participants’ perspectives and sought participant feedback via an online form.

During the 2022-23 APR consultation process, the NDIA received 12 submissions from participants and their representatives. To improve the options available for participant engagement, the NDIA undertook a broader consultation campaign for the 2023-24 APR. This approach recognises that the NDIA puts participants at the centre of everything we do and that many of the ideas about how to make the NDIS better have come from the disability community.

The consultation questions asked participants about:

How much they know about the current price limits.
Their experiences in finding the best price for supports and services within these limits.
How the price limits affect the quality of supports they receive.

The NDIA received 558 responses to the participant consultation questions, with most providing feedback through the online form.

This chapter summaries the feedback received from participants throughout the APR consultation process.

Overview of participant responses

The NDIA invited any participants, family members of participants, carers, and participant advocacy groups with an interest in NDIS pricing arrangements and price limits to make a submission to the APR. Consultation took place between 25 January and 17 March 2024. The participant consultation paper included a Plain English

	Non-Remote	Remote	Very Remote
60%	-	-	-
57%	-	-	-
50%	47%	40%	39%
40%	38%	40%	39%
30%	-	-	-
20%	-	-	-
10%	11%	9%	9%
9%	9%	8%	7%

	Non-Remote	Remote	Very Remote
60%	-	-	-
57%	-	-	-
50%	47%	40%	39%
40%	38%	40%	39%
30%	-	-	-
20%	-	-	-
10%	11%	9%	9%
9%	9%	8%	7%

Comparable government and funding schemes

Comparable government and funding schemes

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Figure 31: Comparison of NDIS price limits to other government schemes

Private billing rates

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Table 21: Summary Statistics of Private Billing Rate Sample, by Therapy Type

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Figure 34: Average Private Billing Rate Compared to the NDIS Price Limit (Dollar Value)

Figure 35: Average Private Billing Rate as a percentage of NDIS price limit

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Mean, Median and 75th percentile billing rates

Psychology

Other therapy types

2023-24 Annual Pricing Review — Page 86 of 352 —

Regressions

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Consultation feedback

Discussion

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Recommendations

Recommendation 4

Recommendation 5

Support Coordination

Context

The NDIS Review

Scheme Statistics

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Table 24: Summary of Changes in Support Coordination Participants, Total Providers and Total Claims

Figure 36: Number of Participants and Providers Claiming Support Coordination Supports, January 2021 to December 2023

6.4 Participants

Figure 37: Participants Using Different Levels of Support Coordination Supports

Providers

6.5.1 The number of providers continues to grow, especially unregistered providers

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Figure 38: Number of Providers by Support Coordination Level, January 2021 to December 2023

Source: NDIS internal administrative data

Notes:

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Figure 39: Changes in Top Ten Provider Market Share Compared to Growth in Support Coordination Providers, January 2021 to December 2023

Figure 40: Top Ten Provider Market Share by Remoteness for Support Coordination Supports, January 2021 to December 2023

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Table 25: Registered Providers by Remoteness for Support Coordination Supports, January 2021 to December 2023

Table 26: Unregistered Providers by Remoteness for Support Coordination Supports, January 2021 to December 2023

Market share reduction of leading providers shows signs of a less concentrated market

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The unregistered support coordination market appears to be structured differently

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Figure 43: Unregistered Providers of Support Coordination Supports by Entity Type and Total Payments, July to December 2023

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Table 27: Claiming Patterns at Price Limit Analysis for Support Coordination Supports, January 2021 to December 2023

Business dynamism in the NDIS support coordination market

Comparison of provider payments for “new” activity and inactivity

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The number of providers continues to grow, driven by unregistered providers

Registered providers show more payment stability than unregistered providers

Figure 46: Provider Continuity by Registration Status and Percentage of Total Payments. Registered Providers (Left) and Unregistered Providers (Right), January 2021 to December 2023

Providers with uninterrupted payment history support more participants

Figure 47: Registered Providers of Support Coordination Supports and Number of Participants Claimed from, January 2021 to December 2023

6.7 Disability Intermediaries Australia Benchmarking Survey

Provider Consultation Feedback

Participant Consultation Feedback

Discussion

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Recommendations

Recommendation 6

Recommendation 7

Short Notice Cancellation Policy

Context

7.1.1 The short notice cancellation policy aligns with the SCHADS Award

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Scheme Statistics

7.2.1 The number of short notice cancellations claims has grown

	Non-Remote	Remote	Very Remote
60%	-	-	-
57%	-	-	-
50%	47%	40%	39%
40%	38%	40%	39%
30%	-	-	-
20%	-	-	-
10%	11%	9%	9%
9%	9%	8%	7%