Joint Standing Committee: NDIS Market Readiness Integra Responses
Introduction
Integra is pleased to continue the dialogue with the Joint Standing Committee around how intermediaries can support and improve NDIS market readiness. Based on our experience in Australia and the United States, and our research on the experience of many European countries using personal budgets, we are confident that effective intermediary services (i.e. support coordination and plan management) can play a vital role in supporting NDIS participants, providers and the agency in realising the scheme’s goals.
The Committee’s enquiries below include items where Intermediaries can provide a valuable service, such as:
- Supporting providers in their transition to a market based system;
- Increasing participants’ readiness to navigate new markets;
- Developing a disability workforce to support emerging markets and the impacts of pricing on those markets;
- Improving quality and safeguards on the development of the market; and
- Improving the accuracy and timeliness of payments to participants and providers.
You will note there are a few common themes throughout our responses that relate to how support coordinators and plan managers can support NDIS market readiness. A brief synopsis of these themes are:
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Provider and Participant Readiness: Plan managers and support coordinators can play a vital role in supporting participants and providers in navigating and effectively realising the benefits of the NDIS. Integra has gone to considerable effort to develop, document & leverage a body of knowledge and develop supportive tools and helpful staff to ensure providers and participants are setup for success.
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Building Participant Capacity (empowerment): Independent support coordinators and plan managers can play a critical role in building participant capabilities and skills to realise their potential to exercise choice and control over their NDIS plan and budget. By assisting participants to “unpack” and understand the complexities of their NDIS plan, they become empowered and informed consumers and “active” participants in their own lives.
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Pricing & Quality and Safeguards: Plan managers enable participants to leverage unregistered providers that are often lower cost. Integra has focused on ensuring
participants have effective quality and safeguards measures in place, such as credentials and insurances.
- Accuracy and timeliness of payments: Integra has built / customised its NDIS plan management information technology and payment processes on systems that are currently making over $US2.5B in annual payments to more than 130,000 participants and 200,000 providers.
Enquiry Reponses
As part of the committee’s role to inquire into the implementation, performance and governance of the National Disability Insurance Scheme (NDIS), the committee will inquire into and report on market readiness for provision of services under the NDIS, with particular reference to:
a. the transition to a market based system for service providers;
SUPPORT COORDINATION
Integra is concerned that unless participants are provided with independent pre-
planning advice regarding all service options, i.e. free of conflict of interest, new
providers will struggle to “break in” to the market and participants will not realise
the benefits of a self-directed program.
PLAN MANAGEMENT
As a plan manager, Integra is currently working with over 1,000 providers who
are often coming from block grant funding and don’t have the appropriate
knowledge, systems or business processes to effectively operate a unit based
invoice system, based on services rendered. Conversely, about 75% of the
providers we work with are unregistered providers, so we provide a vital service
in helping them learn about the NDIS and effectively bill and receive accurate
payments, on time.
Our plan management system removes some of this complexity for providers and
minimises the need for NDIA phone calls or intervention. We offer easy to use
invoicing tools and processes for ease of submission and ensure participants
approve all invoices, prior to payments. In addition, as plan managers we own
the service bookings, billing and payments processes, removing considerable
burden from providers and resulting in fewer calls to the NDIA provider help
desk.
In addition, we have created an internal facing website / tool that our plan
managers and support coordinators use to find suitable providers (registered and
unregistered) and services for participants. We have designed this in such a way
to focus on being “person-centred”, considering unique circumstances and requirements and specialist needs. Providers have been very supportive of this roll out, as it provides them the opportunity to promote their services to a group of participants who are currently shopping for services.
b. participant readiness to navigate new markets;
SUPPORT COORDINATION
There is considerable variability regarding participant readiness (and capacity) to
navigate new markets. Although most participants express an interest and
desire to exercise greater choice and control, most do not have the knowledge
skills or supports to navigate the complexities of the NDIA without significant
support.
The NDIS is a vast and new undertaking, therefore it is understandable that
many participants will find it challenging to navigate their way through the
scheme.
Integra believes “capacity building” hours should be added to all participant plans
enabling the development of individual learning plans to develop self-direction
skills and knowledge in areas of the participant’s choosing. For some participants
“capacity building” may result in reduced dependence on funded supports and for
others it could achieve outcomes that better reflect their needs, wishes and
preferences,.e.g.
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Providing compliments, feedback and complaints,
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Being an “active participant in your therapy”,
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Understanding agency, plan managed and self-management options,
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Preparing for plan review,
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Locating, selecting and contracting service providers.
Capacity building hours should be considered separately from LAC assistance, which is time limited assistance provided to strengthen the participant’s ability to connect with informal, mainstream and funded supports, and aimed to increase capacity to maintain support relationships, resolve service delivery issues, and participate independently in NDIA processes.
PLAN MANAGEMENT
In our experience with the NDIS, participants are excited to realise the benefits of
a self-directed program but aren’t sure what options are available to them and
what the rules are. Intermediaries and plan managers can support participants in
navigating and accessing new markets by ensuring that they understand their
choices, building their capacity, supporting them in locating providers (registered and unregistered), ensuring appropriate contracts / agreements and insurances are in place and generally advocating for the participant.
c. the development of the disability workforce to support the emerging market;
PLAN MANAGEMENT
Unregistered providers and new employment models represent the market disruption necessary to be able to have a future and sustainable workforce with appropriate pricing. Much of the scheme dollars will be used for supports with Activities of Daily Living, that don’t necessarily require extensive / medical certifications and credentials. In our experience in 23 states in the United States, the majority of people with disability who are self-directing their services are also directly employing their workers. These workers are often people that these individuals know through their community who aren’t necessarily disability support workers. These are often neighbours and friends, or people from their church/community groups who can provide these supports.
The Agency has acknowledged that this is needed by allowing self-managing participants to directly employ workers, but we are concerned might have fallen short in ensuring this is done in a safe, legal and consistent way. We strongly encourage the Agency to consider plan managers as a key entity in ensuring all employment models are encouraged and supported, while also being consistent, safe and legal.
Independent support coordinators can also provide oversight of service delivery quality for services “outside of the traditional disability provider network”. At Integra, we routinely survey all our support coordination participants regarding their level of satisfaction with services provided by each of their providers, as well as their knowledge of the complaints process, confidence in raising issues, or providing feedback to their provider.
d. the impact of pricing on the development of the market;
The use of unregistered providers and direct employment can ultimately drive the price point down for supports with Activities of Daily Living and as described throughout, plan managers can be leveraged in such a way to ensure this is done so in a compliant, lawful and safe way.
e. the role of the NDIA as a market steward;
Competent and conflict-free plan managers, with excellent technology enables the NDIA to play a strong role as market steward. As discussed above, the
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Agency can leverage support coordinators and plan managers to manage some quality and safeguards measures associated with participants using unregistered providers. Intermediaries can divert many calls from the NDIA, as we take all questions from participants and providers on plan implementation, service bookings, billing and payments. Clearly this helps free up NDIA resources and capacity.
Intermediaries play a vital role in supporting participants in realising greater choice and control over their NDIS plans. It is our view that with some small changes and consistent standards, NDIS intermediary services could support participants in achieving their goals and the Agency in achieving its financial objectives.
f. market intervention options to address thin markets, including in remote Indigenous communities;
SUPPORT COORDINATION
Very few independent support coordinators will offer assistance in locations where there is significant travel, as travel is unfunded by the NDIS and the fees are often too low to absorb the costs. Initial face-to-face servicing is recognised by the Agency as critical to providing quality support coordination and building participant trust. As a result, support coordination is frequently provided by their direct care provider and consequently the objectivity of the support coordinator role is compromised. In summary, the introduction of a support coordination travel allowance would entice more independent support coordination providers to regional and remote areas.
PLAN MANAGEMENT
Integra plan management services are all provided through a centralised location and world class self-direction technology. Our current participants are supportive of this model and have access to the level of support they choose to effectively identify and contract for services & providers, understand the rules, manage their budget and review all invoices prior to payment. This service could be very helpful to participants in remote areas.
Additionally, the use of unregistered providers and in some cases hiring family
members, will be crucial to ensure full rollout of the scheme in these areas. In the US, we have extensive experience in the direct employment of family members and the enforcement of state level rules and unique tax requirements, associated with the employment of family members.
g. the provision of housing options for people with disability, with particular reference to the impact of Specialist Disability Accommodation (SDA) supports on the disability housing market;
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No response
h. the impact of the Quality and Safeguarding Framework on the development of the market;
Support coordinators and plan managers can support the consistent application of certain minimum quality and safeguard standards. For example, Integra support coordinators provide scheduled participant check-ins regarding the quality of service provision to include:
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How well providers accommodate participant preferences in service delivery
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Awareness of the process to make a complaint or provide feedback to a provider
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How comfortable a participant feels approaching a provider to discuss issues.
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Providing support, skills and training when issues arise
As part of Integra’s plan management enrolment process, Integra requires that unregistered providers provide proof of a successfully completed background check and encourage participants to request appropriate insurances.
All NDIS participants should have the freedom to exercise these choices, while having an independent intermediary partner (plan manager or support coordinator) that will ensure all necessary quality and safeguards are in place, with no extra cost or additional administrative work. This supported freedom of choice is vital to meet the objectives of the Act and can also help address the anticipated provider shortages and current and future challenges of thin markets.
i. provider of last resort arrangements, including for crisis accommodation;
No response
j. any other related matters.
Integra plan management is a holistic intermediary offering and we are currently offering this without adequate funding, as the current pricing (financial intermediary) is intended to primarily cover NDIA billing and provider payment activities. While there is an hourly service (service intermediary) in the price guide, it is extremely rare that we see this added into a participant plan and using an hourly service for this is counter-intuitive to the plan management business model.
We recognise that some of the work we do as plan managers might appear to overlap with the scope of LACs and support coordinators. In our experience, the LACs are sometimes at full capacity and the participant prefers a “one stop shop”, when implementing their plan.
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Scope of Plan Management and Pricing
NDIS plan management services need to be re-scoped and priced to offer an independent, holistic service offering. This will empower NDIS participants to leave their planning session and to effectively take greater control of their plan and to make different choices, should they choose to. We also encourage the Agency to consider creating a small group of independent, well qualified plan managers with sophisticated and proven technology to offer this service. We feel this will result in a higher quality offering, a consistent knowledge base related to plan implementation guidelines and will ease the burden on the Agency by narrowing the number of people billing and contacting the Agency.
Conflict of Interest:
Intermediaries should be separate from support provision, as this is a clear conflict of interest. Plan management and support coordination solutions must be wholly independent, based on person-centered thinking and self-directed principles to ensure the participant is able to truly realise the benefits of the scheme. In addition, it is crucial that intermediary services are clearly and consistently implemented as an administrative cost to the scheme.
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