NDIA Accountability Project

The NDIA’s communication with participants about PSG timeframes for access and planning

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The NDIA’s communication with

participants about PSG timeframes for access and planning

OWN MOTION INVESTIGATION STATEMENT

February 2023

Statement by the Commonwealth Ombudsman, Iain Anderson

CONTENTS

EXECUTIVE SUMMARY ………………………………………………………………… 1

PART 1: INTRODUCTION AND SCOPE OF INVESTIGATION ………………….. 4

Introduction …………………………………………………………………………………………………. 4

The Participant Service Guarantee ……………………………………………………………… 4

The Role of the Commonwealth Ombudsman …………………………………………….. 4

Objective and Scope …………………………………………………………………………………… 5

Investigation Methodology …………………………………………………………………………… 5

PART 2: AN OVERVIEW OF THE PSG AND ACCESS AND PLANNING …… 7

What are the Access and Planning stages? ………………………………………………… 7

Access Stage ……………………………………………………………………………………………………….. 7

Planning Stage ……………………………………………………………………………………………………… 7

Which aspects of the PSG relate to Access and Planning? …………………………. 8

PSG Timeframes for access and planning ……………………………………………………………. 8

PSG Engagement Principles – Transparent …………………………………………………………. 9

How did the NDIA perform against Access and Planning timeframes in 2021–

22? ……………………………………………………………………………………………………………. 10

Improved Participant Experience ………………………………………………………………. 11

PART 3: THE NDIA’S COMMUNICATION ABOUT PSG TIMEFRAMES –

FINDINGS 13

Website ………………………………………………………………………………………………………………. 14

Letters …………………………………………………………………………………………………………………. 17

Telephone …………………………………………………………………………………………………………… 18

PART 4: THE NDIA’S COMMUNICATION WHEN PSG TIMEFRAMES ARE

NOT MET – FINDINGS ………………………………………………………………… 21 APPENDIX A – RESPONSE FROM THE NDIA …………………………………… 23

Commonwealth Ombudsman— The NDIA’s communication with participants about PSG timeframes

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EXECUTIVE SUMMARY

Our role in monitoring the National Disability Insurance Agency’s (NDIA) performance against the Participant Service Guarantee (PSG) is an important addition to the oversight role we already perform in relation to the NDIA.

What we looked at

The PSG was designed to respond to the most common complaints of NDIS participants: delays in decision-making and lack of information. The PSG contains 5 engagement principles and 20 timeframes for NDIA actions and decisions. This investigation considered the appropriateness of the NDIA’s communication with participants about the 6 PSG timeframes related to access and planning, in the context of the engagement principle ‘transparent’.₁ These timeframes apply from when a person first makes an access request to the NDIA up until they receive their first plan as a participant in the National Disability Insurance Scheme (NDIS).

We considered how the NDIA communicates these timeframes on its website to prospective and current participants. We also considered the NDIA’s internal procedures, templates and guidance to assess whether these appropriately support staff to communicate with participants in letters and on the telephone about the progress of access requests or a participant’s first plan.

While the scope of this investigation is limited to communication about the 6 access and planning timeframes, we trust our observations and suggestions will also assist the NDIA to improve the accuracy, clarity and consistency of its communication with participants about other PSG timeframes.

What we found

We acknowledge the NDIA has taken steps to include PSG timeframes in the communications we reviewed. However, we found there is further work required to ensure the NDIA provides participants with accurate, clear and consistent information about the PSG timeframes for access and planning.

₁ Discussed further from paragraph 2.14.

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Our Key Findings

Webpages and templated Internal procedures and The NDIA is not proactively\ncommunicating to\nparticipants where access\nconsistently or clearly National Contact Centre or planning decisions are\neither unlikely to be met or\nhave not been met.

Principles of good public administration applicable to all agencies

This statement identifies several principles of good public administration applicable to all\nAustralian Government agencies. Agencies should:

e Regularly review all forms of communication (including website and letters) to ensure\nthese include clear information about the timeframes an agency is working towards\nfor actions or decisions.

e Ensure policies and procedures enable staff to provide transparent information about\ntimeframes and the progress of decision-making where individuals contact the agency\nwith enquiries about decision-making progress.

e Have processes in place to proactively communicate with individuals who do not\nreceive an action or decision within expected timeframes.

What we suggest

We make 5 suggestions aimed at improving the accuracy, consistency, clarity and\ntransparency of the information provided to participants about the PSG timeframes for access\nand planning.

Suggestion 1

We suggest the NDIA update all relevant website content (including any forms, videos and\ndownloadable documents) to include accurate, clear and consistent references to the PSG\ntimeframes for the access and planning stages.

NDIA’s response: ACCEPTED

Suggestion 2

We suggest the NDIA amend all relevant template letters and attachments for participants to\ninclude accurate, clear and consistent references to the PSG timeframes for the access and\nplanning stages.

NDIA’s response: ACCEPTED

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Suggestion 3

We suggest the NDIA update all policy and guidance documents provided to staff responding to telephone enquiries from participants about access and planning to ensure these documents:

  • include specific PSG timeframes, where these exist, and

  • where relevant, include information about the operation of s 21(3) of the National Disability Insurance Scheme Act 2013 (the NDIS Act) and explain to staff how they should respond to enquiries from participants who have not received a decision within the timeframes set out in s 21 of the NDIS Act.

NDIA’s response: ACCEPTED

Suggestion 4

We suggest the NDIA develop a policy which supports National Contact Centre staff to inform participants about the progress of decision-making against PSG timeframes.

NDIA’s response: ACCEPTED

Suggestion 5

We suggest the NDIA develop a process to communicate timeframe delays with participants who do not receive their first plan within PSG timeframes to advise them that the timeframe has not been met, explain why the NDIA needs more time and when the NDIA will make a decision.

NDIA’s response: ACCEPTED

Summary of NDIA response

The NDIA accepted the 5 suggestions made in this statement (see Appendix A) and provided timeframes to implement the suggestions. We consider the timeframes for implementation are reasonable.

We will monitor, and publicly report on the NDIA’s implementation of these suggestions.

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Commonwealth Ombudsman— The NDIA’s communication with participants about PSG timeframes

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PART 1: INTRODUCTION AND SCOPE OF INVESTIGATION

Introduction

1.1. This is the second investigation by the Ombudsman into the NDIA’s performance against the PSG and covers the financial year 2021–22.

1.2. This statement outlines our investigation under the Ombudsman Act 1976 (Ombudsman Act) into the NDIA’s communication with participants about the 6 PSG timeframes related to access and planning, in the context of the engagement principle ‘transparent’.

The Participant Service Guarantee

1.3. The PSG was designed to respond to the most common complaints of NDIS participants – delays in decision-making and lack of information. It commits the NDIA to timeframes and engagement principles to make it easier for participants and their families to navigate the NDIS.

1.4. The PSG contains:

    -   5 engagement principles designed to give participants, prospective participants,
       and their representatives certainty about how the NDIA will engage with them
         (the PSG engagement principles), and
    -   20 timeframes that apply to NDIA actions and decisions at the access, planning
       and review stages (the PSG timeframes).

Figure 1: Components of the PSG

1.5. The NDIA included the PSG timeframes and engagement principles in its Participant Service Charter (the Charter), which was published in August 2020. At the time of our investigation, the Charter has been in place for 2 years. In our view, it is reasonable to expect the NDIA to have incorporated the PSG timeframes and reflected the engagement principles in its published communication products and internal communication procedures and guidance for NDIA staff.

The Role of the Commonwealth Ombudsman

1.6. The Office of the Commonwealth Ombudsman (the Office) was established under the Ombudsman Act to provide independent oversight of public administration by Australian Government agencies and certain private sector entities. This includes oversight of the NDIA.

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Objective and Scope

Investigation Methodology

1.7. The Office is confined to investigating ‘action that relates to a matter of administration’. In practice, this means, the Office does not investigate the policy decisions made by the government of the day. Rather, we consider whether government departments and statutory agencies act with integrity and treat people fairly in administration.

1.8. As part of its oversight role, the Office takes complaints about the NDIA’s administrative actions and decisions. We can also consider complaints about the NDIA’s Partners in the Community, which include Early Childhood Early Intervention and Local Area Coordinator services.

1.9. The Office will continue working with the NDIA to monitor the NDIA’s performance, including identifying opportunities for the NDIA to improve its approach to administering the PSG pending the making of the National Disability Insurance Scheme Rules (the Rules) under s 204A of the NDIS Act.

Objective and Scope

1.10. This investigation considered the appropriateness of the NDIA’s communication with participants about the PSG timeframes that apply to the access and planning stages under the NDIS. We also considered the NDIA’s approach to communicating with participants about decision-making progress during the access and planning stages. Our consideration of the NDIA’s communication is informed by the ‘transparent’ engagement principle$^\text{2}$ which relates to better practice communication in support of good decision-making and service delivery.

1.11. To assess whether the NDIA’s communication is appropriate, we considered whether the information being provided is accurate, clear and consistent.

1.12. To assess the NDIA’s approach to communicating about decision-making progress, we considered whether staff are appropriately supported to communicate relevant PSG timeframes and inform participants about the progress of decision-making.

1.13. The investigation did not consider: - the NDIA’s communication with participants about PSG timeframes for other stages of the NDIS, such as plan implementation, plan variation or plan review, or - how the NDIA communicates in practice — this means we did not look at actual examples of letters sent to participants or observe telephone conversations between the NDIA and participants.

Investigation Methodology

1.14. We conducted a point-in-time desktop review of the NDIA’s website to consider the information the NDIA publishes for the community (including prospective and current participants) about the PSG timeframes for the access and planning stages under the NDIS. We reviewed: - the NDIA’s online access request form - webpages with information about the access and planning stages under the NDIS

  • Commonwealth Ombudsman— The NDIA’s communication with participants about PSG timeframes for access and planning

        online booklets for participants which contain information about the access and planning stages under the NDIS, and
    the NDIA's online operational guidelines which contain information about the
      access and planning stages under the NDIS.

1.15. We also formally requested information from the NDIA under s 8 of the Ombudsman Act. In response, the NDIA provided template letters and procedural and guidance documents, including telephone scripts for staff used during the access and planning stages, accompanied by a written response to our questions.

1.16. The material listed above formed the basis of our review of the NDIA’s communication with participants about PSG timeframes during the access and planning stages.

1.17. The NDIA provided us with several documents which did not directly relate to communication with participants during the access or planning stages. While these documents informed our overall understanding of the operation of the NDIA, we did not assess or form views on them for the purposes of this investigation.

1.18. We engaged with the NDIA during the preparation of the statement to address information gaps and confirm our understanding of information provided. Our observations, indings and suggestions are based on our assessment of the material provided by the NDIA and the issues we identified.

1.19. The Office provided the CEO of the NDIA with the opportunity to comment on our draft statement. The NDIA’s formal response is attached to this statement as Appendix A. The Office thanks those staff from the NDIA who provided information to assist with this investigation.

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PART 2: AN OVERVIEW OF THE PSG AND ACCESS AND PLANNING

What are the Access and Planning stages?

Access Stage

2.1 To be eligible to receive supports as a participant of the NDIS, someone must:

      make an access request to the NDIA; and
      meet the access criteria.

2.2 To make an access request, someone can either make an application in writing using the NDIA’s Access Request Form or they can apply over the phone. A person who makes a valid access request is a ‘prospective participant’ of the NDIS.

2.3 After a prospective participant makes an access request, the NDIA must either:

      decide whether or not the prospective participant meets the access criteria, or
      request more information from the prospective participant or another person.

2.4 If the person disagrees with the NDIA’s decision that they fail to meet the access criteria, they may request a review of the NDIA’s decision.

Planning Stage

2.5 If the NDIA decides a prospective participant meets the access criteria, the person becomes a ‘participant’ and the NDIA must facilitate the preparation of an NDIS plan.

2.6 A participant’s plan must include two things:

      a statement of goals and aspirations prepared by the participant, and
      a statement of supports prepared with the participant and approved by the
        NDIA.

2.7 The NDIA must decide to approve or not approve the statement of participant support. If the participant does not agree with the supports in their plan, they can request a review of the NDIA’s decision.

2.8 While ‘person’, ‘prospective participant’ and ’participant have particular meanings as outlined above, for the remainder of the statement we will refer to them all as participants.

Commonwealth Ombudsman— The NDIA’s communication with participants about PSG timeframes

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Which aspects of the PSG relate to Access and Planning?

PSG Timeframes for access and planning

2.9 There are 3 PSG timeframes at the access stage:

     1.   After a participant makes an access request the NDIA has 21 days to make a decision on the request or ask the participant for more information.
        
     2.    If the NDIA asks the participant for more information, it has to allow the
         participant 90 days to provide the requested information.
          
     3.    If the participant provides the information the NDIA has 14 days from receiving
       the information to make an access decision.

2.10 Figure 2 outlines how the access timeframes might apply to a fictional participant named Sim.

Figure 2: Access timeframes

2.11 Where the NDIA does not meet timeframes one or 3, the NDIA is taken to have decided that the prospective participant does not meet the access criteria and the decision will be automatically reviewed.

2.12 There are 3 PSG timeframes at the planning stage:

     4.   After the NDIA makes an access decision the NDIA must commence facilitating the preparation of a participant’s plan within 21 days.
      
     5.  The NDIA must approve an adult participant's plan within 56 days of an access decision being made.

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    6.  The NDIA must approve a participant's plan within 90 days for Early Childhood
         Early Intervention participants.

2.13 Figure 3 outlines the planning timeframes might apply to a fictional participant named Sim.

Figure 3: Planning timeframes

PSG Engagement Principles – Transparent

2.14 The PSG Engagement Principles are intended to give participants certainty about how the NDIA will engage with them.

2.15 Each engagement principle is accompanied by a broad statement explaining what the principle means in practice and includes 3-4 specific statements about what the NIDA will do to meet the engagement principle. This investigation focused on the PSG engagement principle ‘transparent’ given its connection to good communication.

2.16 Figure 4 below shows what the NDIA tells participants about the ‘transparent’ gagement principle in the Charter and what they can expect from the NDIA’s engagement with them.

Figure 4: NDIA’s Charter - Transparent

2.17 In our view, to meet the requirement to be transparent and keep participants informed, the NDIA must ensure that participants know about the PSG timeframes and are kept updated about decision-making progress that affects them.

2.18 While the engagement principles are expected to be set out in changes to the Rules in the future, the draft Rules available at the time of our investigation describe the requirement for the NDIA in a similar way to the Charter. It says that to meet this engagement principle,

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the NDIA must (amongst other things), ‘keep participants and prospective participants informed about the progress of decision-making processes under the Act that affect them’.?

How did the NDIA perform against Access and Planning timeframes in 2021-22?

2.19 The NDIA aims to meet PSG timeframes 95 per cent of the time. This means, for example, than for timeframe 6 in the table below the NDIA aims to approve plans (for adult participants) within 56 days of an access decision for 95 out of 100 plan approvals.

2.20 Based on data published by the NDIA in its quarterly reports in 2021-22, on average the NDIA met its target of 95 per cent for the 3 PSG timeframes related to the access stage. The NDIA’s average performance was slightly below its target of 95 per cent for the planning stage timeframes. Table 1 below summarises the NDIA’s performance as reported in its quarterly reports.

Table 1: NDIA’s performance against PSG timeframes for access and planning in 2021-22*

Commonwealth Ombudsman— The NDIA’s communication with participants about PSG timeframes for access and planning

2.21 While it is positive to see the NDIA is meetings its timeframes for the access and planning stages for most participants, these performance figures show that the NDIA is not currently meeting the timeframes in all cases.

For example, in quarter 3 of 2021–22, the NDIA met timeframe 5 for 83 per cent of participants. In that quarter, the NDIA reported it completed 10,815 adult plan approvals.$ This means approximately 1,838 participants did not receive a plan approval within PSG timeframes in this quarter. We discuss the NDIA’s communication with participants who have not received an access or planning decision within PSG timeframes in Part 4.

Improved Participant Experience

2.22 Clear communication with participants about what they can expect to happen and when can improve participant experience by reducing uncertainty.

Ensuring NDIA staff are supported by procedural and guidance documents to provide progress updates to participants who contact the NDIA may assist the NDIA to fulfill its commitment to being transparent and to keeping participants informed as part of the PSG. In our experience, providing clear and timely communication about decision‐making progress may reduce complaints to agencies and our Office.

2.23 The following 2 case studies highlight how a lack of information and communication about decision‐making progress or inactivity can result in frustration for participants and those who support them.$ Both case studies serve to illustrate this point, although only one case study relates to the access and planning stages.

The case studies identified are not intended to attribute blame to either the participant or the NDIA. Additionally, the experiences represented in these case studies are not representative of all interactions with the NDIA.

Case study – Access and Planning: Alphonso

Alphonso experienced a medical episode which resulted in a significant disability and admission to hospital. His nominees lodged an access request with the NDIA. The NDIA made a decision on Alphonso’s access request within 10 days. It took a further 90 days for Alphonso to receive his first NDIS plan. Over these 3 months there were various contacts between the NDIA, a social worker at the hospital and Alphonso’s NDIS nominees. When Alphonso’s nominees contacted the Ombudsman, they told us:

  • For months, it took ages us to get any response at all from the NDIA. Every time we rang up, it was put through to a different person who had no idea what was going on. It seemed like nobody was reading all the medical documentation.
  • Alphonso doesn’t have an allocated NDIS worker, it’s just whoever answers the phone. That is their system. They don’t keep notes up to date and cannot provide information about what’s being done so far. After investigating the complaint and considering all the relevant circumstances, including that Alphonso ultimately received a NDIS plan, the Ombudsman decided that no further investigation of the case was warranted.$

$NDIA (2022) Quarterly Reports | NDIS accessed 7 September 2022. Material in case studies has been paraphrased, and pseudonyms used.

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Case Study – Reviews: Reema

Reema’s family contacted the Ombudsman after becoming concerned about the time it was taking the NDIA to finalise a review under the NDIS Act. When they contacted us Reema’s family told us they had been waiting over 4 months for a decision from the NDIA.

They said they had contacted the NDIA on multiple occasions and spoke with several different officers about the status of the review but were told nothing further than the review was in progress. This frustration led the family to contact the Ombudsman for assistance.

The Ombudsman investigated the complaint and in response the NDIA acknowledged multiple periods of inactivity in Reema’s case including failure to act on several escalation requests from Reema’s family, follow‐up requests not being assigned to relevant areas for action, staff inaction due to movement and delays processing work in the enquiry inbox.

In finalising the investigation, the Ombudsman provided several comments and suggestions to the NDIA about how it could improve handling of cases like this in the future. The NDIA either agreed to or noted all of the Ombudsman’s suggestions.

Commonwealth Ombudsman— The NDIA’s communication with participants about PSG timeframes for access and planning

PART 3: THE NDIA’s COMMUNICATION ABOUT PSG TIMEFRAMES — FINDINGS

31 In our view, ensuring information about access and planning timeframes is accurate, clear and consistent in:

  • communications, webpages and templated letters, and

  • internal procedures and guidance used by staff in their communication with participants

will help the NDIA ensure its communication with participants is appropriate, improves understanding, manages expectations, avoids complaints, and ensures consistency with the transparency engagement principle.

These considerations informed the high-level criteria we used in our assessment set out in Table 2.

Website Letters Telephone guidance
Accurate and Clear Accurate and Clear Accurate and Clear
Does the NDIA state PSG timeframes on webpages and in downloadable documents about access and planning? Does the NDIA state PSG timeframes in templated letters about access and planning? Does the NDIA state PSG timeframes in guidance documents?
Where the NDIA has stated PSG timeframes, are these accurate? Where the NDIA has stated PSG timeframes, are these accurate?
Transparent Transparent Transparent
Consistent Consistent Consistent
Do these documents support NDIA officers to communicate the PSG timeframes to participants over the telephone. Do these documents support NDIA officers to keep participants informed of how their planning or access requests are progressing against the PSG timeframes?

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Website

33 We reviewed the NDIA’s website to identify webpages and downloadable documents containing information about the access and planning stages. Table 3 sets out our findings.

Table 3: NDIA webpages which state PSG timeframes for access and planning

Does it include PSG timeframes for access Webpages
and planning?
“Applying to access the NDIS”* No
Receiving your access decision? No
How to apply”? Yes — timeframe 1
Accessing the NDIS video** No
NDIA’s online Access Request Form?° No
What is an Access Request Form?® No
How the planning process works’ No

3.4 The NDIA publishes booklets to provide information to people applying to access the NDIS or participants awaiting their first plan. These booklets, including Easy Read versions, are available to download from the NDIA’s website. Table 4 sets out which of these booklets contain PSG timeframes for access and planning.

Table 4: NDIA booklets which contain PSG timeframes for access and planning

Participant Booklets Does it include PSG timeframes for access
and planning?
Applying for the NDIS#® Yes — timeframe 1
Creating your NDIS plan?? Yes — timeframes 4, 5 and 6
Applying for the NDIS (Easy Read)*° Yes — timeframe 1
Creating your NDIS plan (Easy Read)** No

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The NDIA publishes its operational guidelines on its website. These documents are based on the NDIS Act and the draft Rules and explain how the NDIA makes decisions. The NDIA publishes these documents to make its decision-making processes more transparent and easier to understand.

Table 5 sets out which of these operational guidelines contain PSG timeframes for access and planning.

Table 5: NDIA Operational Guidelines which contain PSG timeframes for access and planning

Operational Guidelines Does it include PSG timeframes for access and planning?
Yes — timeframes 1 to 6
Operational Guideline — Applying to the NDIS?2
Operational Guideline — Creating your plan**
Yes — timeframes 4, 5 and 6

3.6 The NDIA has not stated PSG timeframes on the majority of webpages that relate to access and planning. While there are some timeframes included in participant booklets, not all timeframes have been included.

  1. We also identified inconsistencies in how the NDIA describes the same timeframe in different communication products particularly in how the NDIA describes the start time for these timeframes and what participants can expect from the NDIA. Tables 6, 7 and 8 outline the inconsistencies we identified.

Table 6: How the NDIA describes timeframe one

Applying for the NDIS Booklet

Once we make our decision, we’ll send you a letter within 21 days to tell you whether you are eligible, how we made the decision, and any next steps.

Operational guideline ‘Applying to the NDIS’

Once we have your application, we have 21 days to decide one of the following:

¢ you’re eligible for the NDIS ¢you’re not eligible for the NDIS ® we need more information.

[Footnote] 32 NDIS (2022) Applying to the NDIS | NDIS, accessed 7 September 2022.

[Footnote] 33 NDIS (2022) Creating your plan | NDIS, accessed 7 September 2022.

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Table 7: How the NDIA describes timeframe 4

Creating your NDIS plan Booklet Operational guideline ‘Creating your Plan’

Following your planning conversation, your | We’ll start creating your plan within 21 days early childhood partner, local area after you become an NDIS participant. cordinator or NDIA planner will start making your plan within 21 days and then submit it to the NDIA who provides final approval

Table 8: How the NDIA describes the requirements of timeframe 5

Operational guideline ’Applying to Operational guideline ‘Creating your Plan’ The NDIS’

If you’re aged 7 or older, we must approve If you’re 7 or older, we aim to approve your your first plan within 56 days after you first plan within 56 days after you become a become a participant. participant.

3.8 The NDIA’s operational guideline, ‘Applying to the NDIS’ (the guideline) includes all 6 PSG timeframes for access and planning. In our view this document provides the clearest explanations of the PSG timeframes and provides the NDIA with a good example which it could replicate in its messaging across its communication products to ensure consistency.

3.9 The guideline was the only external document we identified which explains to participants that if the NDIA does not meet timeframes 1 or 3 the NDIA has to treat this as though it has decided the prospective participant is not eligible to access the NDIA and the decision is automatically referred to review.™ To improve accuracy and consistency across communication products the NDIA should include this information in other locations.

3.10 While the guideline provides an example of clear information about the PSG timeframes it may not be easy for participants to locate because there is no direct link from the NDIA’s webpages about access and planning to this guideline.

3.11 ’In our view participants may overlook this information if it only appears in a separate document and not on relevant webpages. To improve clarity, transparency and the likelihood of participants finding this information the NDIA should ensure PSG timeframes are on all relevant webpages.

3.12 The website is likely to be a resource for people who have already made an access request and are awaiting a decision or plan as well as people considering applying to access the NDIS. It is important for the NDIA to include information consistently across all of the webpages which contain access and planning information.

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Suggestion 1

We suggest the NDIA update all relevant website content (including any forms, videos and downloadable documents) to include accurate, clear and consistent references to the PSG timeframes for the access and planning stages.

Letters

3.14

We considered a range of letters provided to us by the NDIA. These related to access requests, requests for information and notifying participants they had met or had not met the access requirements.

3.15

We observed some of the access and planning letters contain PSG timeframes. However, some crucial letters:

  • do not include PSG timeframes
  • do not clearly explain to participants when a particular timeframe starts or finishes, and
  • include outdated information.

3.16

For example, the 2 template letters for when someone meets the access criteria do not provide PSG timeframes. The letters tell the recipient that the NDIA will contact them in relation to the next stage of commencing their plan but do not specify the PSG timeframe for this step. The letters also contain outdated information about the NDIS rollout across Australia which was completed on 1 July 2020. The NDIA could improve participants’ understanding and expectations of the planning process by including specific PSG timeframes. The NDIA also sends participants a planning factsheet with this letter confirming they have met the access criteria. This document does not include any PSG timeframes.

3.17

Another example of the issues we identified is the Access Request Receipt – ARF Receipt letter. It says participants can expect an outcome on their access request within 21 days. It also tells participants that the NIDA will contact them if the NDIA needs further information to decide if the person meets the access requirements. In our view the NDIA could improve the wording in its letters to make it clearer for participants that the NDIA has 21 days to do one of 3 things: decide the person meets access requirements, decide the person does not meet access requirements or request further information.

3.18

It is good practice for agencies to include accurate, clear and consistent information about timeframes in letters. In our experience, keeping individuals informed about when to expect a decision or what the next steps of the process are can reduce anxiety and frustration about decision‐making processes.

3.19

The NDIA should review its suite of templated letters to ensure participants receive accurate, clear and consistent information about the access and planning timeframes.

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Suggestion 2

We suggest the NDIA amend all relevant template letters and attachments for participants to include accurate, clear and consistent references to the PSG timeframes for the access and planning stages.

Telephone

3.20

We considered a range of guidance documents which support NDIA staff to respond to participant enquires about the access and planning stages. This guidance includes a mix of procedural instructions, suggested scripting and policy.

3.21

We identified gaps in the 3 standard operating procedures which include guidance for the NDIA’s National Contact Centre staff to respond to telephone enquiries from participants about the access or planning process. These documents relate to access requests and eligibility, access requests in progress, and planning.

Standard Operating Procedure – access requests and eligibility

3.22

The standard operating procedure covering access requests and eligibility tells staff how they should respond to participant requests for updates on the progress of access requests.

3.23

The procedure informs staff, ‘After the access request is received as valid, the NDIS must make a decision, or request further evidence, within specific timeframes. The document does not mention the PSG or advise staff that the NDIA must make the decision with 21 days.

3.24

The procedure provides guidance to staff about how to respond to participants who have been waiting more than 21 days for an access decision. In our view the guidance provided to staff is not clear. In one section of the document staff are advised to apologise for the delay, confirm the application is awaiting assessment and inform participants that their enquiry will be escalated to another branch for action. The next section of the document advises staff to apologise for the delay and confirm the application is waiting assessment. Staff are advised only to escalate the contact if priority criteria for escalation are met.

3.25

This procedure does not contain any guidance for staff on the operation of s 21(3) of the NDIS Act. This section says if the NDIA does not make an access decision or request information from the participant within 21 days of the participant’s access request the NDIA is taken to have decided the participant does not meet the access criteria. The result is that the NDIA is required to review the decision.

3.26

The procedure informs staff where a participant meets the access criteria the participant will commence development of their first plan either with an NDIA staff member or a planner who is external to the NDIA. Staff are advised that timeframes for planning conversations will vary and cannot be advised. In our view this information does not appropriately support staff or provide participants with clear information about the 2 PSG timeframes which apply to planning.

Standard Operating Procedure – access requests in progress

3.27

The standard operating procedure covering access requests in progress also tells staff how they should respond to participant requests for updates on the progress of decision‐making.

Commonwealth Ombudsman— The NDIA’s communication with participants about PSG timeframes

for access and planning

3.28

In relation to timeframes for completing access decisions the procedure states ‘Under no circumstances is the National Contact Centre to provide any timeframes around Access decisions’. The procedure does inform staff that the NDIA has 21 days to make an access decision and 14 days to make an access decision after making a request for information under s 26 of the NDIS Act. The document does not mention the PSG.

3.29

Where participants have been waiting less than 21 days for an access decision, staff are advised to apologise for the delay and confirm the application is waiting assessment. Where the participant has been waiting more than 21 days, the National Contact Centre is to internally escalate the contact. There is no guidance provided to staff about what they are to advise participants in this case or about the operation of s 21(3) of the NDIS Act.

3.30

In relation to planning the procedure informs staff that where participants who met the access criteria contact the NDIA for an update, they should be told that an ‘NDIS representative will contact you soon’. In our view this information does not appropriately support staff to provide participants with clear information about the 2 PSG timeframes which apply to planning.

Standard Operating Procedure – Pre‐planning, Planning and Scheduled Review Check Ins

3.31

This standard operating procedure for the NDIA’s National Contact Centre relates to pre‐planning, planning and scheduled review check ins. As the scope of our investigation was limited to access and planning, only those parts of this standard operating procedure form part of our assessment.

3.32

This procedure does not include the PSG timeframes for planning. It informs staff that there may be a delay between a participant’s planning meeting and when they will receive their plan. Staff are informed the timeframe could be 4 weeks between this meeting and receiving an approved plan.

3.33

Staff are told to tell participants that it can take 4 weeks between the planning meeting and receiving an approved plan. For ‘persistent callers’ staff are told to check details in the system, including the date of the planning meeting, and reiterate that it may take 4 weeks to receive a plan. Callers are invited to contact the NDIA again if they are waiting more than 4 weeks. Where the National Contact Centre staff member identifies the person has already been waiting more than 4 weeks from their planning meeting, they are to escalate the contact internally.

Strengthening these guidance documents

3.34

By updating relevant guidance documents to include the PSG timeframes for access and planning NDIA staff may be better positioned to inform participants about their operation. In our view this may assist in promoting participant understanding of the process and managing expectations around key decision‐making points.

3.35

By developing a policy and process to support staff to provide progress updates to participants who call the NDIA, the NDIA may similarly be in a better position to improve participant experience and minimise the risk of complaints. This is because participants would have greater certainty about when things will happen, what the next steps will be and the timeframes for their completion.

Commonwealth Ombudsman — The NDIA’s Communication With Participants About PSG Timeframes For Access And Planning

Suggestion 3

We suggest the NDIA update all policy and guidance documents provided to staff responding to telephone enquiries from participants about access and planning to ensure these documents:

  • Include specific PSG timeframes, where these exist, and
  • Where relevant, include information about the operation of s 21(3) of the NDIS Act and explain to staff how they should respond to enquiries from participants who have not received a decision within the timeframes set out in s 21 of the NDIS Act.

Suggestion 4

We suggest the NDIA develop a policy which supports National Contact Centre staff to inform participants about the progress of decision-making against PSG timeframes.

Commonwealth Ombudsman— The NDIA’s Communication With Participants About PSG Timeframes For Access And Planning

PART 4: THE NDIA’S COMMUNICATION WHEN PSG TIMEFRAMES ARE NOT MET – FINDINGS

4.1

Agencies should update individuals on the status of their requests for services, either manually, through online portals, automated systems such as SMS messaging or tracking applications. If it appears unlikely that an agency will complete an action within a standard timeframe, or a timeframe provided to an individual, this should be recorded and communicated to the individual with an explanation and revised timeframe.

4.2

In these situations, transparent communication about the NDIA’s performance and clear information about what will happen next may reduce feelings of uncertainty, anxiety or frustration for participants who are waiting for a delayed access or planning outcome and may assist in reducing complaints.

4.3

As identified in the NDIA’s performance reporting in Part 2, there are some instances where the NDIA is unable to meet the PSG timeframes for access and planning decisions.

4.4

The NDIA informed us that its systems can identify participants who are at risk of not receiving actions or decisions within PSG timeframes or participants who have not received an action or decision within PSG timeframes. This information is shared with senior staff within the NDIA through briefings and meetings.

4.5

These reports are also provided to staff so they can contact participants awaiting decision or actions to progress these to finalisation. We understand this contact is focused on finalising the action or decision as opposed to communicating that the NDIA has not met a PSG timeframe.

4.6

The NDIA advised its current business system has limitations and it is unable to automatically send communication to participants where the NDIA may not or does not meet a PSG timeframe. The NDIA advised it is planning to rollout a new business system, PACE, that will:

  • provide staff with real time Service Level Agreement counters and tracking for PSG work items
  • provide participants on the PACE business system with the ability to view the current status of a PSG related work item via the Participant Portal, and
  • enable the NDIA to notify a participant of the status of their PSG work item via instant communication from the PACE business system (such as via email and/or SMS).

4.7

We acknowledge the NDIA’s commitment to improve how it tracks and communicates with participants about its progress against PSG timeframes. While we accept that the NDIA is moving towards being able to proactively communicate with participants, we understand PACE will not be fully rolled out until 2023.

Commonwealth Ombudsman— The NDIA’s communication with participants about PSG timeframes

for access and planning

4.8 While waiting for the rollout of PACE the NDIA should develop a process to communicate with individuals where the PSG timeframes have not been met so that participants are aware of this and have certainty about when a decision will be made.

4.9 It seems reasonable that where the NDIA has not met timeframes 1 or 3, the subsequent communication with participants would inform them that an automatic decision has been made and the decision will be reviewed, consistent with the operation of s 21(3) of the NDIS Act. The letters provided by the NDIA to inform our investigation did not confirm if it has template letters for this purpose.

4.10 However, for timeframes 5 and 6, the communication should advise participants that the relevant timeframe has not been met, explain why the NDIA needs more time and when the NDIA will make a decision. This approach to communicating with participants would be consistent with how the NDIA committed to communicate with participants where it does not meet PSG timeframes for internal reviews. In the operational guideline for reviews the NDIA tells participants that where a PSG timeframe is not met the NDIA will communicate with participants to explain why the timeframe has not been met and when the decision will be made.36

Suggestion 5

We suggest the NDIA develop a process to communicate timeframe delays with participants who do not receive their first plan within PSG timeframes to advise them that the timeframe has not been met, explain why the NDIA needs more time and when the NDIA will make a decision.

36 NDIS (2021) OG Reviewing Our Decisions v5.0 APPROVED ‐ EXTERNAL 2022‐07‐01.pdf (page 9), accessed 7 September 2022.

GPO Box 700

Canberra ACT 2601 1800 800 110 ndis.gov.au

Mr Iain Anderson Commonwealth Ombudsman Office of the Commonwealth Ombudsman

Via email: iain.anderson@ombudsman.gov.au

Dear Mr Anderson,

Thank you for your letter dated 24 February 2023 providing your Statement of the investigation and findings into the National Disability Insurance Agency’s (NDIA) communication with participants about Participant Service Guarantee (PSG) timeframes for access and planning. I appreciate your acknowledgement that the Agency has taken steps to include PSG timeframes in the communications reviewed and your observations on the further work required to ensure the Agency provides participants with accurate, clear and consistent information about the PSG timeframes for access and planning. The Agency is pleased to accept all five recommendations and will progress work to address each recommendation. The Agency will work closely with your team as we progress implementation of the recommendations. Please refer to the attached “Response from the NDIA” for further detail on next steps and anticipated timeframes. I look forward to our continued engagement with your Office as you undertake the ongoing monitoring and reporting of the implementation of the PSG. Should you wish to discuss any aspect of the draft report or the Agency’s response, please contact Mr Andrew Maitland, General Manager Operations and Support Division.

Yours sincerely,

Rebecca Falkingham Chief Executive Officer National Disability Insurance Agency

3 March 2023

Appendix A: Response from the NDIA

Introduction

The National Disability Insurance Agency (NDIA) acknowledges receipt of the Office of the Commonwealth Ombudsman’s report under section 8(3) of the Commonwealth Ombudsman Act 1976 and provides the following responses to the recommendations. The NDIA accepts all the Ombudsman’s recommendations, and appreciates the advice received. The NDIA acknowledges that there has been a number of issues in relation to ensuring participants are fully advised of the Agency’s Participant Service Guarantee (PSG) obligations due to a range of identified business system limitations. Progression towards the development of a bespoke customer management system designed specifically for the NDIA is expected to be piloted later this month with full roll-out in early 2023. This new system will also support improvements in how the NDIA communicates with participants through all correspondence methods - letters, emails and in person - via a program of work to help us successfully design, build, and transition to a new business system, PACE. PACE will fully replace the current Services Australia SAP CRM business system. This work redesigns our system and processes to improve the participant experience. The aim of this work is to:

  • Make sure we have a system which can deliver on the outputs of co-design activities.
  • Deliver on the Participant Service Charter, the Participant Service Guarantee, and the Participant Service Improvement Plan.
  • Improve systems and internal processes, and the way the NDIA works.
  • Respond to feedback from frontline staff, partners, and the wider disability community.
  • Improve the participant experience with the NDIS and ensure the Agency has the systems, processes, and controls in place.

Commonwealth Ombudsman— The NDIA’s communication with participants about PSG

timeframes for access and planning

e Implement changes to the legislation that took effect on 1 July 2022, including the introduction of the PSG.

The design and build of PACE have been strongly influenced by ongoing consultation with staff, NDIS Partners in the Community and participants, as well as the outcomes of prior consultation with participants.

PACE will improve how participants interact with the Scheme and provides the flexibility needed to deliver improvements across access, planning and NDIS lifecycle activities. One of the key features in the design of PACE is that it is a case management system and service standards, such as PSG timeframes, are core to the infrastructure of the case processes. This design enables the Agency to provide users of PACE with access to real-time, system automated PSG timframe data relevant to the cases they (or their team) are assigned without the need for manual recording and off-system reporting.

The NDIA is re-writing all access and planning letters for PACE. This includes providing information about PSG timelines where relevant, what happens next in the access and planning process and how to contact us for more information. The Agency has committed significant investment and resourcing into the development of our new business system to ensure that that the participant experience is optimal and tested. The Agency will balance any immediate, low- cost improvements that can be made now with the benefit of an improved, participant centric system into the future.

The updated and improved access and planning letters is available in PACE for real time testing in Tasmania, which commenced 14 November 2022.

National roll out of PACE is planned in 2023.

OFFICIAL

Commonwealth Ombudsman— The NDIA’s communication with participants about PSG timeframes for access and planning

Pages requiring content audits to ensure the content links back to the main PSG timeframes page:

Access https://www.ndis.gov.au/applying-access-ndis/how-apply#what-s-next https://www.ndis.gov.au/how-apply-ndis/what-access-request-form#supporting-evidence- form https://www.ndis.gov.au/applying-access-ndis/how-apply/receiving-your-access-decision https://www.ndis.gov.au/applying-access-ndis/how-apply/information-support-your- request/providing-evidence-your-disability#how https://www.ndis.gov.au/applying-access-ndis/how-apply/information-gps-and-health- professionals/applying-access-ndis-faq https://www.ndis.gov.au/applying-access-ndis/how-apply/information-support-your- request/providing-evidence-disability-children#submitting-evidence Operational Guidelines: Access to the NDIS (OG microsite). Planning

https://www.ndis.gov.au/applying-access-ndis/how-apply/receiving-your-access-decision#if- you-are-found-eligible https://www.ndis.gov.au/participants/using-your-plan/who-can-help-start-your- plan#implementation-meeting https://www.ndis.gov.au/participants/how-planning-process-works#receiving-your-approved- dis Plan https://www.ndis.gov.au/participants/creating-your-plan/receiving-your-approved-plan

OFFICIAL

Commonwealth Ombudsman— The NDIA’s communication with participants about PSG

timeframes for access and planning

The NDIA is committed to ensuring all Participant Service Guarantee (PSG) timeframes and relevant content are consistently available across the NDIS website on relevant web pages, forms, documents, and videos.

The NDIA regularly reviews NDIS website content to ensure it is effective and meets the needs of our participants and website visitors including managing participant expectations on timeframes related to access and planning. Although the website promotes PSG timeframes in multiple locations (listed above), we acknowledge that the information could be clearer, easier to find, and more consistent.

The NDIS digital delivery team have recently completed website benchmarking which showed the NDIS website structure is over 2,000 pages long over 5 tiers of website navigation. The benchmarking showed that the size of the website hinders navigating the site, popular pages are located deep in the navigation and visitors used site search rather than menus, due to confusing navigation and content duplication. The team are currently working on the next steps to address consistent content issues, duplication, and navigation on the website.

The NDIA will promote the PSG timeframes related to access and planning by linking back to a centralised location on the Participant Service Guarantee page. This will allow for a simpler approach that still gives people the information, without overcomplicating the page content. The Agency believe it is a lower risk to link back to the timeframe information in a centralised location (on the PSG page), rather than duplicating information about timeframes across multiple pages. This approach also reduces the risk of having out of date information at any one time.

The NDIA is committed to improving the user experience for our approximately 500,000 visitors every month. Recent feedback tells us clearer content and reduced volumes of

Commonwealth Ombudsman— The NDIA’s communication with participants about PSG

timeframes for access and planning

content on the website would be beneficial. The proposed solution will limit the amount of on-page text and ensure an improved experience while still promoting timeframes. Using this approach will also make it easier to update if PSG timeframes or content change.

Recommendation 2 Accepted The Agency accepts the recommendation made by the Ombudsman’s Office. A key component of this activity is identifying manually activated and printed letters and attachments requiring immediate change. All manually activated letters can be reviewed, revised, and updated within shorter timeframes than those which are embedded within ourparticipants to include accurate, clear, and consistent references to the PSG timeframes current SAP CRM as system generated correspondence. These letters will be prioritised for review and remediation by February 2023.

The NDIA’s experience in arranging for business system generated letters to be updated in our existing SAP CRM indicates that it is extraordinarily complex, inefficient, and costly. Automating system generated correspondence in the current SAP CRM business system is considered a significant system enhancement and will take time, incur substantial costs, and divert resources from building the new business system, PACE. As the NDIA has moved towards the development of our own purpose-built business system, resources previously attached to the Agency by Services Australia have been gradually withdrawn leaving only minimum capacity to maintain the current SAP CRM system.

The Agency is re-writing system generated access and planning letters in readiness for the PACE trial in Tasmania, which includes providing information about PSG timeframes where required, advice about what happens next in the access and planning process and, how to contact us for more information if needed. These template letters and attachments will be

Commonwealth Ombudsman— The NDIA’s communication with participants about PSG

timeframes for access and planning

available in PACE for real time testing across access and planning processes in the new PACE CRM system trial commencing in November 2022. The Agency currently includes information in access and planning letters about PSG timeframes and uses our continuous improvement framework and feedback about our resources to improve letters to ensure consistency and accuracy of how we communicate PSG timeframes. The advice received from the Office of the Commonwealth Ombudsman provides further feedback to which the Agency accepts and will adopt as discussed in this response.

Further improvements will also be made as part of the National implementation of PACE in 2023.

Recommendation 3 Accepted The Agency accepts the recommendation made by the Ombudsman’s Office.

We recommend the NDIA update all policy A comprehensive stocktake and review of all articles relating to PSG timelines will be completed by 31 December 2022.responding to telephone enquiries from participants about access and planning to ensure these documents: This will include a review of all Operational Guides, Standard Operating Procedures, Knowledge Articles, NCC Scripts and work instructions to ensure they accurately reflect PSG timeframes and are consistent with information available to all NDIA Staff (including Partners in the Community (PiTC) and NCC telephony staff). This timeline will allow the review to be completed and material updated before the National roll out of PACE. Where relevant, include information about the operation of s 21(3) of the Act 2013 (the NDIS Act) and explain to staff how they should respond to enquiries from participants who

  • include specific PSG timeframes, where these exist, and
  • where relevant, include information about the operation of s 21(3) of the Act 2013 (the NDIS Act) and explain to staff how they should respond to enquiries from participants who

Commonwealth Ombudsman— The NDIA’s communication with participants about PSG

timeframes for access and planning

Individuals have not received a decision within Individual knowledge articles are categorised based on the different sections of the NDIS Act, the timeframes set out in s 21 of the including specific topics such as access decisions, reassessment, and reviews. This supports NDIS Act. NCC agents to confidently speak to the correct PSG timeframe for the appropriate action that is underway with a participant’s access or planning process. The Agency will review these articles to action the advice received in relation to s21(3) ensuring staff can appropriately explain decisions and timeframes to which the Agency is required to respond.

The current SAP CRM Business system has a number of limitations which prevent NCC agents being able to advise callers on the status or progress of their request, the new PACE system will remove these limitations. Whilst the Agency is transitioning to the new PACE business system a stronger NCC PSG framework will be developed to improve the experience of callers to the NCC including the development of a PSG communication Policy as outlined in recommendation 4.

Recommendation 4 Accepted The Agency accepts the recommendation made by the Ombudsman’s Office.

We recommend the NDIA develop a policy As stipulated in Recommendation 3, the Agency will complete a comprehensive stocktake and which supports National Contact Centre staff review of current guidance materials to ensure consistency across all knowledge management to inform participants about the progress of platforms which will be completed by 31 December 2022.decision-making against PSG timeframes. The Agency will support collaboration across key business areas including Participant Advocacy, Co-design and Engagement, Service Guidance and Practice, Policy, Partner Performance, and the Contact Centre Branch to commence a coordinated approach to inform policy development.

                                              The Policy will support how all frontline staff, including NCC telephony staff, inform
                                                          participants about the PSG timeframes to provide an enhanced participant experience and

Commonwealth Ombudsman— The NDIA’s Communication With Participants About PSG

timeframes For Access And Planning

The Policy Will Provide A Better Understanding Of The Agency’S Commitment To The PSG Timelines And What Will Happen Next. The Policy Will Also Inform An Agency Wide Approach To Ensure That All Frontline Staff Understand And Are Supported To Communicate PSG Timelines To Participants And Potential participants.

The Agency Will Strengthen Guidance Through:

  • The Revision Of Standard Operating Procedures And NCC Knowledge Articles And Scripts;
  • Development And Alignment Of A Complimentary Learning And Development Package That Informs, Educates, And Empowers Staff To Feel Confident Speaking To PSG Timeframes When Engaging With Participants;

The Commencement Of Policy Preparations And Discovery Will Commence Mid November 2022.

Simultaneously, The Ndia Will Make It Mandatory For All Ncc Staff To Enrol In The Ndias Existing Learning Module “Understanding The Participant Service Charter And Participant Service Guarantee” To Immediately Improve Their Understanding Of Psg Timeframes.

Recommendation 5 Accepted The Agency Accepts The Recommendation Made By The Ombudsman’S Office, Noting The Concerns Raised Are To Be Addressed With The Introduction Of The New Business System (PACE). We Recommend The NDIA Develop A Process to communicate timeframe delays with The management and communication of PSG timeframes in the agency’s current SAP CRM business system has significant limitations, including the inability to automatically generate within PSG timelines to advise them that The timeframe Has not been met, explain why communications such as pre-call text, SMS, or correspondence to a participant when a PSG Timeframe is close to lapsing. This Is Primarily Due To The introduction of the PSG post

Commonwealth Ombudsman— The NDIA’s communication with participants about PSG

timeframes for access and planning

the NDIA needs more time and when the NDIA development of the SAP CRM system in 2016, and the manual system workarounds the will make a decision.

These workarounds include the manual recording of start and end data points for PSG service standards in uncontrolled interaction data templates on SAP CRM by frontline staff. Linking automated correspondence to this data is not currently possible, leaving the only option to automate correspondence in the current SAP CRM business system through significant system enhancements which will potentially take longer than what will be achieved through transition to PACE and incur substantial costs.

With the learnings of the current system’s limitations, and the additional work required by staff to maintain PSG records within the SAP CRM system, the NDIA have ensured that the design of the new business system (PACE) addresses these limitations with embedded PSG and SLA timeframes as well as on-system reporting, escalation, and management of SLAs.

One of the key features in the design of PACE is that it is a case management system and service standards, such as PSG timeframes, are core to the infrastructure of the case processes. This design enables the Agency to provide users of PACE with access to real-time, system automated PSG timeframe data relevant to the cases they (or their team) are assigned without the need for manual recording and off-system reporting. The Agency have also ensured the service standards for each case are configurable; mitigating the risk of a hard coded system that is difficult to change as currently endured with the current SAP CRM system.

Additional functionality delivered through PACE includes embedded system escalation for cases nearing PSG timeframe expiry, as well as a SLA milestone tracker visible on each case that displays a countdown of the time remaining to complete the case to the end user. Real- time operational reports will be available to identify cases at risk of lapsing the related PSG

Commonwealth Ombudsman— The NDIA’s communication with participants about PSG

timeframes for access and planning

The timeframe, and on-system work re-assignment capability will enable the Agency to action cases for priority where required.

All these features will be available in PACE for the real time testing in Tasmania, commencing November 2022.

Given the PSG service standard metrics are embedded within the PACE business system, it will enable the Agency to easily display these timeframes to external interfaces of the system such as the Participant Portal. An example of how this will be used to improve the participant experience is by providing participants with the capability to view the status of a PSG related work item on the Participant Portal and Mobile App. This functionality will be deployed as part of the National Rollout of PACE in 2023. As previously noted in Recommendation 2, the Agency is committing significant resources to ensure the successful roll-out of our new business system in 2023 and considers that this will ensure we are best placed to deliver on our PSG commitments.

It is important to note that the consideration of PSG service standards within PACE are also dependent on the finalisation of the NDIS Rules for PSG, which are currently in draft. Further work and enhancements to the PACE Business System will be driven based on the outcome of these Rules.