ADA WoA Inflation Update

May 2024

Analytics, Data and Actuarial (ADA) Division

Introduction

ADA analysis indicates that most of the historical intraplan inflation observed in the Scheme over the 12 months to February 2024 was driven by a relatively small group of participants, with about 25,000 participants driving 62% of intraplan inflation, and of those, 3,500 participants driving 42% of intraplan inflation. These are referred to as the ‘high inflation’ cohorts for this pack.

ADA were tasked to further investigate these groups, including splits of this cohort by:

• SIL status
• Intermediaries (Plan Manager/Support Coordination)
• Streaming
• Age
• State/Geography
• Plan size

[Image not converted to Markdown – “Image of Table 1 and Chart 2” – check the source PDF page for the actual content]

Table 1: Intraplan inflation (excl. price indexation) in 12mths to Feb24 by age band and plan budget

| Age | Plan Budget | # of participants | % | Annualised Inflation net of indexation | % |—|—|—|—|—| | 0-14 | 0-$200,000 | 26,828 | 27% | $239m | 7% | | $200,000+ | 1,052 | 1% | $101m | 3% | 15+ | 0-$200,000 | 47,314 | 47% | $902m | 27% | | $200,000+ | 24,973 | 25% | $2,061m | 62% | Total | | 100,167 | 100% | $3,304m | 100%

Over the 12 months to Feb24, intraplan inflation was driven by a relatively small group of participants aged 15+ with annualised plan budgets of over $200,000.

This group of ~25,000 participants made up 62% of the observed intraplan inflation (excl. price indexation effects).

[Image not converted to Markdown – “Chart 2: Selected group of participants with by intraplan inflation band” – check the source PDF page for the actual content]

Of this group of ~25,000 participants, around two-thirds (67%) of the intraplan inflation was driven by a small group of around 3,500 participants who had high proportional intraplan inflation, of 40% or more.

1. SIL Status

# Participants	Intra-plan inflation	Intra-plan inflation Rate
SIL	Non-SIL	%SIL
High Contributor Group (~25,000 participants) (Age 15+, Annualised Budget $200,000+, >$1 intraplan inflation over 12 months to March 2024)	12,351	12,584
High Inflation Rate Subset (~3,500 participants) (Age 15+, Annualised Budget $200,000+, 40%+ intraplan inflation over 12 months to March 2024)	1,424	2,091
All active participants at Feb24 (Age 15+, Annualised Budget $200,000+, ~60,000 participants)	33,378	27,843

• Given the annualised budgets of $200,000+, a relatively high number of SIL participants is expected in the two ‘high inflation’ cohorts.

• 50% of the high contributor group are SIL participants and 41% of the high inflation subset being identified as SIL. This compares with 55% of active participants in the Scheme under the same age and budget criteria identified as SIL.

• Therefore, ‘high inflation’ cohorts driving intraplan inflation skew toward non-SIL participants.

• Marginally higher rates of intraplan inflation are also observed for non-SIL participants in both cohorts.

2a. Intermediaries — Plan Management* (1)

% of Participants	Intra-plan inflation	Intra-plan inflation Rate
Self Managed	Plan Managed Partly	Self Managed
High Contributor Group (~25,000 participants) (Age 15+, Annualised Budget $200,000+, >$1 intraplan inflation over 12 months to March 2024)	3%	7%
High Inflation Rate Subset (~3,500 participants) (Age 15+, Annualised Budget $200,000+, 40%+ intraplan inflation over 12 months to March 2024)	2%	5%
All active participants at Feb24 (Age 15+, Annualised Budget $200,000+, ~60,000 participants)	2%	6%

• There is a significantly higher concentration of plan management in the selected ‘high inflation’ cohorts (80% and 87% with at least partial plan management) than Scheme average group with comparable budgets and ages (75%).

• Analysis suggests participants who are at least partially plan managed see higher rates of intraplan inflation than participants in other plan management types.

*Note: a hierarchical approach is used to categorise participants into these plan management categories, which is generally expressed as Self-Managed being the highest in the hierarchy, followed by Plan Managed, then Agency Managed.

2a. Intermediaries — Plan Management* (2)

• The top 20 plan managers for the ‘high contributor group (~25,000 participants) is shown in the table to the right.
• Most (19 of 20) of these plan managers are also in the top 20 for the high inflation subset (~3,500 participants).

Note: a hierarchical approach is used to categorise participants into these plan management categories, which is generally expressed as Self-Managed being the highest in the hierarchy, followed by Plan Managed, then Agency Managed.

#	Plan Manager Name	# Participants	Average Intraplan Inflation per participant
1		1,685	$88,792
2		1,004	$70,017
3		792	$83,810
4		646	$94,618
5		466	$93,989
6	s47G - business information	942	$75,210
7		469	$79,661
8		417	$83,479
9		387	$88,212
10		371	$87,715
11		408	$71,547
12		279	$100,864
13		274	$92,412
14		232	$94,726
15		127	$159,139
16		228	$86,818
17		177	$105,275
18		126	$140,518
19		124	$123,385

2b. Intermediaries — Support Coordination

# Participants	Intra-plan inflation	Intra-plan inflation Rate
With Support Coordination	No Support Coordination	% with SC
High Contributor Group (~25,000 participants) (Age 15+, Annualised Budget $200,000+, >$1 intraplan inflation over 12 months to March 2024)	22,126	2,809
High Inflation Rate Subset (~3,500 participants) (Age 15+, Annualised Budget $200,000+, 40%+ intraplan inflation over 12 months to March 2024)	3,091	424
All active participants at Feb24 (Age 15+, Annualised Budget $200,000+, ~60,000 participants)	54,596	6,625

• The ‘high inflation’ cohort are have high levels of involvement with intermediaries, with around 90% of individuals receiving support coordination services. This may be expected given the high-needs nature of this group, as similar proportions are seen for comparable active participants with similar budgets and ages.
• Around 54% of all participants aged 15+ are receiving support coordination supports.
• Of those receiving support coordination, the majority (~90%) received Level 2 support coordination, similar to overall support coordination use in the Scheme.
• The 10% of the ‘high inflation’ cohorts who did not receive support coordination had similar proportional contributions to intraplan inflation and did not appear to have significantly different average intraplan inflation rates (and were in some cases marginally higher).

3. Streaming Type

% of Participants	plan inflation Rate
Super	Super
General	Supported

High Contributor Group (~25,000 participants) (Age 15+, Annualised Budget $200,000+, >$1 intraplan inflation over 12 months to March 2024) | 4% | 10% | 58% | 16% | 10% | 2% | 22% | 18% | 17% | 19% | 24% | 26% |

High inflation Rate Subset (~3,500 participants) (Age 15+, Annualised Budget $200,000+, 40%+ intraplan inflation over 12 months to March 2024) | 4% | 9% | 54% | 17% | 14% | 2% | 88% | 85% | 89% | 96% | 102% | 102% |

All active participants at Feb24 (Age 15+, Annualised Budget $200,000+, ~60,000 participants) | 3% | 9% | redacted: s47F | 17% | 9% | 1% |

• For the participants in the ‘high inflation’ cohorts, the majority were streamed as ‘intensive’ (54% and 58%). This is within expectation for this group, overall active participants at similar ages and budgets had similar proportions in this stream (61%).

• We observe higher numbers of complex stream participants, particularly for the ‘high inflation rate subset of 3,500 participants, than comparable participants in the overall Scheme.

• Further, those in the complex stream had higher rates of intraplan inflation than those in other streams (noting small numbers of participants in YPIRAC mean that results for this category may not be reliable).

4. Features by age

High Contributor Group (Age 15+, Annualised Budget $200,000+, ~25,000 participants)

600 120%

—

500 100%

400 80%

300 60%

20! 0%

10 / 0%

0 0%

15to25 25to35 35t045 451055 55to65 65to75
Age Band

Contribution to scheme intraplan
inflation ($m)

oOo
as

N
Implied Intraplan Inflation (% 

= Contribution to scheme intraplan inflation ($m) @lmplied Intraplan inflation

• Within the cohorts of interest, participants aged 55 to 65 contributed the most to intraplan inflation in absolute terms.

• However, ages 15 to 25 showed a relatively higher inflation rate.

• When compared to others in the Scheme at the same age and budgets, the ‘high inflation’ cohorts also showed a skew towards higher participant numbers in these younger (15-25) and older (55 to 65) age groups. This potentially corresponds to key transitional life stages for a participant.

High Inflation Rate Subset (Age 15+, Annualised Budget $200,000+, 40%+ intraplan inflation ~3.500 participants)

600

500

400

300

200

100

40%
; i i /

0%

~ rs ° o

15to25 25to35 35to45 45to55 S55to65 65to75
Age Band

= Contribution to scheme intraplan inflation ($m) @lmplied Intraplan inflation

30%

25%

% of participants
= N

2

Age Distribution Comparison

25 to 35 35 to 45 45 to 55 55 to 65
Age Group

mHigh Contributor Group (~25,000)
High Inflation Subset (~3,500)
mu Comparable Scheme Active Participants (~60,000)

65 to 75 75 to 85

5. Features by state

High Contributor Group High Inflation Rate Subset (Age 15+, Annualised Budget $200,000+, ~25,000 participants) (Age 15+, Annualised Budget $200,000+, 40%+ intraplan inflation ~3,500 participants)

• Across both ‘high inflation’ cohorts, most intraplan inflation can be attributed to VIC, NSW, and QLD due to higher numbers of participants from these states.

• SA has the highest intraplan inflation rate across both groups.

6. Features by plan size

High Contributor Group High Inflation Rate Subset (Age 15+, Annualised Budget $200,000+, ~25,000 participants) (Age 15+, Annualised Budget $200,000+, 40%+ intraplan inflation ~3,500 participants)

9,000                                  9,000
32%                                    
8,000                                  8,000
                                       
7,000                                  7,000
25%

6,000                                  6,000

5,000                                  5,000
16%

4,000                                  4,000

3,000                                  3,000
10%

2,000                                  2,000
1%

1,000                                  1,000
2% 3% 

0.2mto 0.3mto 0.4m to 0.5m to 0.6m to 0.7m to 0.8mto 0.9mto 1m+ 0.2m to 0.3mto 0.4mto 0.5mto 0.6mto 0.7mto 0.8mto 0.9mto
0.3m 0.4m 0.6m 0.7m 0.9m 1m 0.4m 0.5m 0.6m 0.7m 0.8m 0.9m 1m
Annualised Plan Valves os) Annualised Plan Values (S)

• Most plans across both ‘high inflation’ cohorts have an annualised plan values of $200k to $300k, noting the minimum annualised budget of $200k applied to these groups.

Appendix - Case studies

Illustrative examples of participants with intraplan inflation well in excess of average (Case studies 1 – 4)

Overspending patterns around Behaviours of Concern, SIL supports, and Support Coordinator and Plan Manager influence (Case studies 1 – 4)

Page 11 of 15

Case Study 1: $2.82M Spent Compared to Approved Funding of $931k for 12 Months

Participants continuing to claim level of supports not funded — behaviours of concern

A participant with recorded disabilities of Autism (level 3) and moderate ID. Escalating behaviours since 2019, verbal and physical aggression reported and concerns for mental health raised. Multiple hospital admissions redacted: s47F - personal privacy since 2020. In June 2022, the participant’s annualised budget was

aa funded, started accessing 24/7 1:1 supports approx Oct 2021, and 24/7 2:1 supports Jan 2022. H&L decision Aug 2022 to fund 12hr/day 1:1 and 12hr/day 2:1 support.

Support Coordinators and Plan Managers advised numerous times 3:1 not funded, however attempts to date to bring spend in line with plan have been unsuccessful.

Sept 2022: Plan Manager Aug 2023:

May 2023: Plan Manager withdraws services “due to ongoing issues regarding non compliant invoices…despite our best efforts to work with the plan nominee”

May 2024: “After 21 June no unregistered providers will be authorised by Agency Management” =a

Aug 2023. Contact Agency co ned

Nov 2024 April 2024: Support Coordinator notified that plan budget is being exhausted, as anticipated, this was also formally flagged by the 3 Plan Manager

May 2023:

Aug 2023: Contact with 3 Plan Manager unable to continue 3:1 support as funding almost exhausted.

Interplan inflation: August Interplan inflation: December Interplan inflation: February > interplan inflation: April

2023 a 2023 > 2024 oan 2024

12-month plan approved. Annualised one 64% | of >.

12-month plana Annualised a 16% een Ei 12-month 98% ny 12-month 90%|iaof 6-month As at 2/5/24, 16%

12-month plan approved. 6-month plan approved.

Annualised budge on Annualised budge Nm

6% of budget used within month budget used expected duration Intraplan inflation: 184% Intraplan inflation: 228% Intraplan inflation: 163% Intraplan inflation: 144% within 12% of expected

• Plan approved due to core funding exhausted Support Coordination . “nearing depletion of * Plan approved due to funding almost exhausted — additional supports funded

• Plan approved due to funding in previous plan managed * Step down in funding did not get implemented in * Awaiting AAT outcome

• Plan approved due to funding exhausted * Plan approved due to funding

• “Accessed supports need to b utilised in accordance wi [ppt’s] plan”

“We are in understanding that the plan has been created with specific hours and support ratio in mind, however it is the understanding that once a plan is created it is a participants choice and control to use hours as they see needed.” *

12

• Response from Plan Manager in Aug 2023 after delegate contact advising budget overutilised, reiterating what supparts had been funded in the plan and advising “Payments are expected to be in accordance with the intention of the NDIS and the request for 3:1 is outside of the expected plan spend. Funding above the allocation is not in line with the plan allocation and is not considered reasonable and necessary based on current evidence.“

Funding increase due to addition of 30 days STA, an increase in 24/7 2:1 days funded, and possible error in previous budget calculation.

Case Study 2: $2.1M Spent Compared to Approved Funding of $772k for 20 Months

Participant continuing to claim level of SIL supports not funded as well as supports not funded in the plan Participant has recorded disabilities of Cerebral Palsy and Moderate Intellectual Disability.

27 plans have been approved since January 2017 (the longest plan duration 7 months) with a history of overutilisation. Participant contacted multiple times prior to May 2022 and advised to spend supports in line with plan funding. Attempts to date to bring spend in line with plan have been unsuccessful. The participant has submitted multiple requests for additional supports to be funded.

November 2022: s100 lodged, original decision confirmed.

February 2023: Support Coordinator advised the participant believed “they were the operations manager for the SIL provider and were calling in staff”

March 2023: s48 lodged requesting AT and increased core supports.

January 2024: s100 lodged. Decision pending — additional information requested

September 2022	November 2022	March 2023	October 2023	January 2024
Interplan inflation: +19%	Interplan inflation: 0%	Interplan inflation: -2%		Interplan inflation: 0%
12-month plan approved. Annualised budget: 89% of 12-month budget used within 21% of expected duration Intraplan inflation: 322%	12-month plan approved. Annualised budget: 93% of 12-month budget used within 27% of expected duration Intraplan inflation: 247%	12-month plan approved. Annualised budget: 96% of 12-month budget used within 65% of expected duration Intraplan inflation: 48%		12-month plan approved. Annualised budget: As at 3/5/24, 74% of 12-month budget has been used within 31% of expected duration

• Plan approved due to funding exhausted

• All supports excluding Core DA & SCCP again ‘stated’ to try to address overutilisation

• Plan approved to implement * Plan approved due to funding * Plan approved to include AT. All other supports unchanged

• All supports excluding Core DA & SCCP again ‘stated’ to try to address overutilisation

*Figures excludes Capital support funding.

The participant has accessed core SIL supports exceeding 2:1 24/7 and supports not funded across multiple plans

Case Study 3: $647k spent compared to approved funding of $403k for 53 months

Evidence of Support Coordinator influencing overutilisation

s47F - personal privacy Participant met access under unspecified intellectual disability in 2018.

Participant was supported by two different support coordination providers over 2 years to access supports not funded, including STA, SIL and Supports in Employment, leading to plans being overutilised.

Participant was supported to move to SIL prior to an Agency decision on SIL suitability, and remains living in SIL arrangement despite HaL decision of not SIL suitable.

October 2021: Support Coordinator requested review “Moved to SIL accommodation, “[SC] will look further into this to find out what her needs further assistance.”

May 2023: Support Coordinator “advised that the employment supports is currently being paid for by NDIA”. Participant is supported through DES so previous support coordinator gave the approval for [ppt’s] to move into SIL accommodation and have her funding utilised for this.

May 2023: “[SC] advised me that [ppt’s] previous support coordinator gave the approval for [ppt] to move into SIL accommodation and have her funding utilised for this.”

December Interplan inflation: 99%

July 2021 Interplan inflation: -6%

February 2023 Interplan inflation: 121%

12-month plan approved (auto extended to 24-month plan). Annualised budget: s47F - personal privacy

24-month plan approved. Annualised budget: s47F - personal privacy

24-month plan approved. Annualised budget: s47F - personal privacy

24-month plan approved. Annualised budget: s47F - personal privacy

106% of 24-month budget used within 78% of expected duration Intraplan inflation: 64%

37% of 24-month budget used within 79% of expected duration Intraplan inflation: 34%

• Plan approved due to change of circumstances – s47F - personal privacy

50% of 24-month budget used within 47% of expected duration Intraplan inflation: 140%

• Plan approved due to funding exhausted s47F - personal privacy

s47F - personal privacy §_ S4/F - personal privacy

Support Coordinator has supported participant to access supports not funded or a higher level of supports since 2019. No evidence of discussion about spending in line with plan. However Support Coordinator was advised to “arrange with providers to claim invoices and that when funding is close to exhausted contact the NCC and request an escalation based on plan has no funds”

• December 2022 interaction by NCC Customer Service Officer relating to claim enquiring about progress of s48 request.

FOI 22/24-1280

Case Study 4: $645k spent compared to approved funding of $260k for 26 months

Participant continuing to access SIL supports following Home & Living decision of not SIL suitable and Plan Manager influence

A participant with recorded disabilities of Cerebral Palsy and Mild Intellectual Disability, moving into SIL arrangement in June 2022.

resulted in 3 plans being overutilised.

s47F - personal privacy This has

January 2023: Support Coordinator stated that she March 2024: Agency contacted Support Coordinator has had toredacted s47F - personal privacy and discussed the risk of delivering support model

February Interplan inflation: February Interplan inflation: September 2022 +20% 2023 +82% 2023

24-month plan approved. 24-month plan approved. 12-month plan approved. Annualised budget Annualised budget Annualised budget s47F - personal privacy

99% of 24-month budget used 97% of 24-month budget As at 2/5/24, participant has used 92% within 50% of expected duration used within 30% of expected duration of 12-month budget Intraplan inflation: 98% Intraplan inflation: 223% used within 62% of intended plan duration.

• Plan approved as a scheduled reassessment * Plan approved to implement redacted Personal Privacy, Hal decision of SIL not suitable = decision confirming previous SIL not suitable decision. s47F - personal privacy s47F - personal privacy

The participant’s Plan Manager, Support Coordinator and SIL provider are from the same provider company**

This provider has collectively contacted the Agency on more than 25 occasions since November 2022 enquiring about additional funded supports and stating the participant is at risk of homelessness if additional funding for SIL is not received.

*Figures excludes Capital support funding. ** Company appears to be owned by the participant’s Support Coordinator.