General issues around the implementation and performance of the NDIS Submission 74
There are unintended consequences of the NQSC’s application of the quality and safety compliance audits to provide supports to NDIS participants. All of the various touch points in the supply chain for the provision of assistive technology, or AT as it is known, have been caught up by the NDIS legislation, resulting in disproportionate costs.
The intention is to apply a quality system that is “proportionate” to the size and risks of the businesses supplying NDIS participants, one that is based on a structure of sole trader or company, not on turnover. In this sector there are few if any “sole traders” but often they are small family businesses, 2 to 5 staff, i.e. SMEs. Due to this, most providers of AT supports fall outside the definition of a business eligible for the simplified ‘verification’ audits.
The provider registration audit requirements duplicate other quality system processes and place unfair compliance costs on SMEs. This is encouraging a growing number of AT providers to either not supply to the NDIS or to close their doors, greatly impacting local employment and causing a loss of specialist skills to the sector. This is more profound in the thin support areas, i.e. regional areas, where choice is already limited i.e. many small, family AT businesses serving the local community.
The cost to supply AT supports to NDIS participants is already substantial due to the systems and processes that have been imposed on the sector since the introduction of the NDIS. The original intention was to encourage market growth including competition, however the opposite is unfolding, with businesses withdrawing their services to NDIS participants, thereby further reducing choice and control.
Typical reported audit fees are well over $8,000 P.A. plus travel/accommodation/meal expenses, in addition to the paperwork processing and preparation costs internal to their business prior to the Audit, which has been 2 days in most cases. For many SMEs, this would be a substantial part of their annual profits.
It is important to note that the provision of AT under State/Territory funding schemes and the Department of Veteran’s Affairs does not require such audits. They recognise the important regulatory roles played by the Therapeutic Goods Administration coupled with Australian Standards testing for AT, along with the ACCC. They also understand the value of occupational therapists’ oversight of AT trials, scripting, delivery and setup.
The circumstances are unfolding, i.e. allied health professionals electing to refuse to supply to NDIS participants due to the prohibitive costs to comply. ATSA are dealing with requests from members for advice as they have been informed that the local healthcare professionals have elected not the be registered to supply NDIS clients due to cost. Now they are weighing up their circumstances, as their ability to provide AT will be greatly affected, i.e. AT supply is via a script, without scripts from healthcare professionals there can be no sales, so why spend money to be registered as an NDIS provider?
ATSA is highly concerned that if urgent action is not taken there will be a collapse in the supply of AT across Australia to NDIS Participants.
David Sinclair Executive Officer