To Whom This May Concern,

I wanted to get in touch to express our significant concerns regarding the recommendation of the Independent Pricing Review to have multiple rates for Therapeutic Supports for clients based on their ‘complexity’ and the in-principal acceptance of same by the NDIA.

We see multiple and significant negative implications of this policy being adopted, and we hope that the Joint Standing Committee will take this into account at their June meeting.

Firstly, the premise of “dividing up” participants under the scheme into three “Levels” is reductionist and dehumanising. It devalues us as professionals and, more importantly, it devalues and dehumanises participants. To reduce a child to a GMFCS level and therefore say to them that their therapy has less value than what the scheme will offer a child with a different GMFCS level is absurd and ignorant. It completely ignores the best practice evidence base of family/child/person-centred care in natural environments. In our experience, the level of “complexity” of providing allied health services to support a child or adult with a disability is aligned only very loosely with measures of their physical disability and often there is no relationship at all. EVERY participant who needs therapy services deserves good quality, evidence-based care from a suitably qualified, skilled and appropriately supervised practitioner who is actively engaged in professional development.

The same amount should be payable per hour of therapist time regardless of the experience of the professional or the complexity of the case. For less experienced professionals there is an additional supervisory and professional development cost in ensuring best practice and more experienced professionals deserve to be paid more for their advanced skills and expertise and the relevant pay award clearly states this. The only possible exception to this situation would be if NDIS considered that for some complex cases there should be an additional loading in recognition of the fact that those complex cases may involve additional out of session activities/workload, for example, extra phone calls, research, record keeping and preparation. This would be dependant on how this complexity was defined as well as how all-inclusive pricing is calculated and we would unequivocally state that a purely physical disability based measure would be completely inappropriate. NDIS is purchasing a time-based service when paying for allied health services and should pay a fixed per unit (hourly) price because regardless of so-called complexity the same number of units has still been provided and the per unit cost to deliver good quality services is comparable.

We believe that these decisions are being made based on evidence from other professions (such as physiotherapy) or professional workgroups (such as DVA, TAC or workcover), without consideration of the unique factors of working as an therapist in the field of disabilities under the NDIS.

Working as an OT is unique in both the means of delivery but also the contextual factors around the therapeutic relationship. This is why I decided to become an OT over another Allied Health Discipline.

We are generally a one-to-one service, typically best delivered in the client’s own home or other relevent environment (Kindy/School). Unlike DVA clinic-based physiotherapy, we are not able to see more than one client at a time - and under the NDSI, neither are they!

I note that the recommended rates range from $110 - $190 per hour. Despite reading the full IPR document as released, it remains very unclear as to what a lower versus higher complexity client entails in terms of therapeutic directions or expectations, goals and outcomes. Or who shall be making these decisions.

I am thoroughly disappointed that psychology is seen as a more “remunerable” therapy to PWD in the space of NDIS which is in fact meant to be focused on increasing the Functional Capacities of PWD, where Physiotherapy and Speech Therapy alongside OT are integral.

It is also very unclear who is responsible for determining the appropriate complexity rate for each PWD. We wish to know - Are the families now to be burdened further with increased requirement to further inform the LAC/ECEI partner at the planning stage of their families or PWD complexity levels to ensure adequate funding?

As an experienced Occupational Therapist

my decision on the complexity and needs of a child with a disbility or multiple disabilities that I am working with, versus planners who are largely under-experienced in many disabilities, and their unique presentations, prognosis and outcomes expected, may be extremely different.

Is this based on an outcome number on the PEDI-CAT? How are the cutoffs justified for each level? Solely behavioural or physical and hence not taking into account familial situation and risk factor. How will this affect children with autism and their packages who are already largely underfunded due to poor Pedi-Cat atings.

The plans in these cases would be made with a lower expected need for therapeutic intervention/hours of service, and then this funding would be gone in a shorter period of time - then what happens to these PWD? They wait half to 3/4 of a year for further funding? Im appalled at this devaluation of individual needs.

As a small business the lower classification hourly rate is not fiscally viable. As a result, we would need to make the decision to decline these referrals and this is against our personal and professional morals and ethics. We would expect that business factors would force most small OT providers to make this decision also, reducing further the services available to people with disability. We are already hearing of multiple OT businesses, ranging from sole traders to mid-sized teams, making the decision to de-register from the NDIS due to financial pressures.

On page 79 of the Independent Pricing Review document, it is stated that the decision to have various rates is based on this practice being used in comparable schemes, such as TAC, WorkSafe, DVA and SIRA. I would dispute that DVA uses a system of various hourly rates based on complexity level – instead they use time based fees to denote complexity of intervention for the client. SIRA does not have set fees for OT services, but they do for Physiotherapy, Chiropractic and Osteopathy. The various Worksafe schemes around the country each have their own schedules of fees, but none of these are as low as $110 per hour, as far as we can determine. In opposition there is capacity to charge the gap fee directly to the client between the funded fee and the actual fee - something disallowed by NDIS. Additionally most of these schemes utilise a ‘session’ fee rather than a per hour fee. That time can be as little as 20 mins in some cases and therefore for a true hourly rate must be at least doubled.

We see that this decision is devaluing some Allied Health Services – we note that Psychology service rates have been increased, and other Allied Health service rates have been significantly decreased in all but one of the categories. Our time is just as valuable when seeing a less complex client as it is when seeing a more complex client. For less complex clients services are generally completed in less time - therefore at less cost to the client and hence the NDIS. For those with more complex needs, simple things take longer. Even those OTs who are less qualified and thereby can see clients with less complex need still require supervision and support which cannot be recouped within this ‘complexity’ based model.

In terms of managing this change, we are already struggling with the cost of the administration required to work under the NDIS, with issues such as different service booking and invoicing procedures based on the type of management of the Plan, navigating the Portal, and managing the immense amount of time that it akes for payment issues to be resolved. We would estimate our Administrative support has had to increase by many hours per week just to manage these issues. To then add in further complexity is an unsound decision and will become unmanageable within

Further, we would question who it is that makes the decision regarding the ‘complexity’ of the client – Planners? We already see significant variation between Plans, often related to the knowledge and skill of the Planner completing the Plan development. We often see evidence that Planners are not skilled in identifying the functional implications of a person’s disability – for example many clients who require Support Coordination and Plan Management due to their cognitive and physical conditions or life circumstances (CALD, illiteracy) are being left Self-Managing and without Support Coordination as Planners are not identifying the need.

What will happen when a client’s ‘complexity’ level changes and more funding is required urgently – ‘Change in Circumstances’ applications are taking many months to be processed at the moment, and they require significant support from Providers in regards to evidencing the need in reports, and assisting clients to navigate the system and escalate their requests.

• We acknowledge that support workers, such as attendant carers, may have a need to remunerate workers when higher level of skills or experience is required. However, this is a very different role to that of the OT, and this policy should not be translated to our profession.

related to general private practice, and the implications of private pay clients in some cases needing to pay more for therapy than funded clients. I feel this is unsustrainable and this has further implications for private practice established with fees often $160-175 for the preceding 2-4 years. This is absolutely detrimental to the number and bredth of service providers in the market.

Decreasing our prescribed fee (both directly through NDIS funded clients but also incidentally through a decrease in fees payable by private clients), devalues our profession and leads to increasing workloads, poorer quality therapy and hence, outcomes are poorer or take longer.

Given the aim of Early Intervention in particular is to see improved outcomes to decrease relience on the system in the longer term, I am failing to see how this can be a tenable solution.

We look forward to hearing how the joint standing comittee will be responding to these proposals.