The MAJOR Concerns with the Reform
Bill
Functional Eligibility:
NDIS is already meant to look at impairment, not label, but they don’t – they look at the label in an attempt to justify minimizing supports, by taking a functional capacity assessment that states 12-19 hours of support required per day, and saying “well, this person has 4 disability level conditions, and 3 medical – so we will fund 2 hours a day”
They already ignore actual levels of impairment, even after someone has had to prove EACH listed disability as meeting all the disability criteria, namely permanence (have tried all treatments available and appropriate) and significant impairment caused and lifetime support required for it…
Which leads into my next point, changes to access – AN ATTACK ON POOR
AND MIDDLE INCOME DISABLED PEOPLE
Schedule 1 Part 8 and 9
The changes they want to make under section 25A, means that if a person cannot afford to access a treatment, or they would need to fly and stay in another state to try the treatment (even if they can’t afford it) – they will be denied access. So this is doing exactly the opposite of what auntie Pauline has suggested, it’s not means testing NDIA so that people who need it most can access it – it is punishing poor people for not being able to afford the treatment.
And to show you the extent of this disgusting suggestion, I’ll again use the example of someone with complex and multiple disabilities:
A person has autism, they have PTSD because they were forced to do uncomfortable things and mask all their life and OCPD as a response to that fear of “doing it wrong” as they had always been screamed at for it and punished. Whether or not we agree that all of these directly relate to autism is immaterial, the point is that all of these can be debilitating. Now they need to seek out each medical and non-medical treatment available. Public health has years long waitlists, if you even get in at all (I was referred a year ago for ECT and have heard nothing back, the ECT is to address the depression/PTSD that “may” cause fibromyalgia or FND.
Medicare
Gives only 5 sessions per calendar year for specialists (OT, speech, dietician, physio, ect)
10 Sessions for psychology
FND requires the “neuro” version to ensure they don’t worsen the condition, autism requires a specialist in autism and likely PDA who is also trauma informed.
Let’s say each requires 6 months of OT, speech and physio…
Explain to me exactly how this should happen?
And perhaps an equally major concern, is whether a treatment is deemed appropriate if it reduces for example PTSD impairment, but causes insomnia so severe that sleeping tablets can’t counteract it… or causes OCD to go into overdrive and has the patient pulling out large patches of their hair every day for hours at a time…
PART of the reason NDIS has “blown out” and is so much larger than medicare, is because medicare DOES NOT take care of the chronically ill, nor those between disability and chronic illness.
It also doesn’t provide for the stepping stone to be able to access NDIS – the ability to get a functional capacity assessment done (8-15 hours of OT)
BeƩer AlternaƟves to address the concerns – TARGET PROVIDERS FIRST, not parƟcipants
Scaled pay rates for sole traders and other businesses without overheads like rent and utilities of an actual office/clinic
The NDIS has “Price Limits”, which most providers use, and misrepresent, as the set rate. There is no competition in any of the markets in NDIS, and greed drives people out of direct employment and into self-employment, meaning companies struggle to retain sufficient choice of workers for participants, and greedy individuals charge twice their worth in any other industry unqualified and inexperienced.
Example using support workers:
Actual worth on SCHADS (casual rate to account for leave) + superannuation + $1/hour for business costs (insurance is less than 50c/hr for full time hours)
Why so little? Because that’s all the additional cost they require over 38 hours a week. The taxpayer is not there to subsidize their desire to work less than that while ripping off people with disabilities. Because they already pay 9.09% less in employment related expenses than employees do – because they don’t charge GST, but can claim it back on expenses.
Level 1 SCHADS employees
Off the street with an ABN only, maybe a police check if participants are lucky.
$32.875 casual
$36.82 including superannuation
Charging the maximum $70.23 means they are wasting $32.41 per hour of taxpayers’ money.
Over 46 weeks (so assuming they use all the sick and annual leave they accrue), that’s $56,652.68 per year PER WORKER of wasted taxes
That means 1 individual working hard to earn around $190,000 per year, is paying JUST THE EXCESS that one of these people are overcharging disabled people
Assuming only 1,000 of these workers exist (and we all know that they actually make up closer to the majority) that’s $56.6 million in wasted taxes alone
Level 2 SCHADS employees
Cert 3/4 or sufficient industry experience required (which many sole traders don’t even have)
Fair cost is $45.3455
Over 46 weeks (so assuming they use all the sick and annual leave they accrue), that’s $43,498.98 per year PER WORKER of wasted taxes
That means 1 individual working hard to earn around $160,000 per year, is paying JUST THE EXCESS that one of these people are overcharging disabled people
Assuming 10,000 of these workers exist, that’s $434.989 million per year in wasted taxes alone
Level 3 SCHADS employees
Cert 4 PLUS relevant industry experience minimum OR tertiary qualification
Fair cost is $55.11
Over 46 weeks (so assuming they use all the sick and annual leave they accrue), that’s $26,429.76 per year PER WORKER of wasted taxes
That means 1 individual working hard to earn around $110,000 per year, is paying JUST THE EXCESS that one of these people are overcharging disabled people
Assuming 50,000 of these workers exist, that’s $1.32 BILLION per year in wasted taxes alone
So just in support workers, in an example where qualification standards are reversed, we have nearly $2 Billion wasted
This is also based on the community rate, not even home care, and only week day daytime rates, consider:
$98.83 Saturday
$127.43 Sunday
$156.03 Public holiday rate profits
Now, they may argue that it doesn’t take into account note taking time, which brings me to my next recommendation…
Audit invoices and inform participants properly, instead of stating “the provider knows”
Note taking is charged by SOME/MOST (but not all) therapists DOUBLE
They fraudulently charge 1 hour face to face and then spend anywhere between 40 50 minutes doing actual face to face, and then charge another anywhere between 15-30 minutes of note taking/planning. When questioned why the session is shorter than billed, they will say “the hourly rate provides for note taking and planning”… Which is true, as in the maximum rate is what it is to account for UNBILLABLE admin tasks like notes. And notes (and any other non-face-to-face tasks) may only be billed if it is PARICIPANT NEED, NOT legal requirement, business policy, compliance or standard practice.
Yet providers big and small, therapy, support coordination and support work alike, bill for note taking and tell participants it is a requirement (NDIA, legal or otherwise).
Therapists bill $193.99/hour
Support work rates are in the first recommendation
Between 15 and 30 minutes are billed PER SHIFT/SESSION for notes to cover themselves, not for participant needs
You can do the calculations on taxpayer funds wasted on this
Travel to and from participants
Mobile therapists not only don’t have occupancy costs (rent, utilities, ect), but then charge the maximum rate AND travel. If a business makes the choice to only work in
the community, why should they be paid for travel time when there is no option to go to a clinic.
They are already covered with the profit from saving on overheads and occupancy, more than covered.
Sole Trader support workers and mobile therapists pretend their home is their “usual place of work”, despite participants arguing that the community is their “usual place of work” and they can only charge between participants – unless they work more than 50% of the time in their home. Paid work, not admin, note taking (billed or unbilled).
Clarification has been sought in writing several times, each time conflicting. Set the record straight in the next Pricing Arrangements and Price Limits
Mandatory calculation of actual cost of running their vehicle for each business/provider, and they can only claim that much from participant plans
As with many other sections, the expectation that participants should negotiate, when there is a significant imbalance of power, is a ridiculous expectation from NDIA
Self-management flaw
Complaints about the cost of plan managers and how participants should self manage, are overshadowed by the fact that “SM participants do not have to hold to PAPL”. What does this mean?
Providers take this to mean THEY don’t have to keep to PAPL Participants get rorted more and faster
NDIA-management flaw
Unless it has recently changed, providers can simply upload invoices and these simply get paid. No checks and balances, no seeing whether services were actually rendered with participant or nominee.
Calculate that fraud
Other price gouging/fraudulent charging methods
Domestic and household assistance charged as personal care (which is shower, toilet, feeding, etc) at $70.23 instead of $59.06 or $58.03
Disregarding the requirement to bill ACCURATELY leads to 4 hour shifts that have SCP, domestic assistance and personal care in it – charged at one flat rate in the highest category possible
It also leads to “incremental charging” where mostly support coordinators and support workers will bill in 10, 15, 30 minute or 1 hour increments – regardless of whether it was a 2 minute call. Or it will be 2 minute call billed as 15 minutes because they updated notes or their CRM (unbillable admin). This is a persistent issue.
“Minimum shift” fraud, where providers will state (despite the code of conduct disallowing it) they will only do 2 hours minimum – or even 4. This removes choice and control, once in the agreement, participants feel locked in and even if they do try to change it – will be charged the minimum regardless, or will be left without support.
It also includes cleaners and gardeners who will bill 2 hours plus 30 minutes travel as a minimum, despite “being in the area” that day.
So participants whose integrity or knowledge cannot be bent, go without supports, because they will not let their funds be rorted and they feel a duty to the taxpayers that fund their supports. Others fold, because their need for support drives them to – or because they believe these people should be paid that.
I had a gardener quote me $142.45 for what took 2 people 20 minutes the last time I had gardening services. Privately, he charges $70/hr “accurately”. So what would cost $46.67 privately, he wants $142.45 because I’m disabled and there is literally nothing extra he needs to do.
Now, why not just pretend to be private? Because the NDIS cap is $56.98 per hour and I’d be made to pay a gap of $8.68 per fortnight, which, between myself and 3 special needs kids – I don’t have.
Why not go self-managed? Again, because I can’t work or study anymore, and 1 hour of admin requires 6 hours of a nap for my brain – because of FND, the disability I don’t have listed, because between the other ones that are listed – I can’t manage my own health, treatments etc. and I won’t overpay a grub, and I can’t pay a family member a fair rate to help me either.
Cancellation sole traders should not be able to charge 7 days regardless
Participants should be informed that the 2 weeks notice to cancel service agreements, does not mean the provider gets paid a 2 week short notice cancellation
Providers telling participants they need to inform them if they are sick, when the participant does this, the PROVIDER cancels or manipulates participant into cancelling – and if under SNC time, bills participant for a cancellation the provider made
Double dipping on cancellation providers charging cancellation (or travel) fees, despite filling the worker’s shift with other billable work or not needing to pay the worker
Participants working as supports that they deliver under NDIS… I know… I KNOW you are thinking what the damn hell!? But yes, participants have cleaning, gardening, social and community participation, support coordination and personal care funded – but somehow can provide some or all of these supports to others… at those same maximum rates.
Now this is where people get angry with autistic people on the NDIS, and as an autistic person, I understand completely. Because they want to argue body doubling or “just because I can do for others paid, doesn’t mean I can for myself for free”, or “disabled people can work in any industry they want” or even “working doesn’t preclude you from NDIS support…
All those things are true, the question is – should it be. Is it reasonable and necessary to fund cleaning for a professional cleaner? Is it reasonable and necessary to fund any form of support work for someone who can do it for others, under their own business entity no less? I think not. Not when we are looking at cutting whole groups of participants because of too much funding being used. When there are people who can’t work, study or maintain a livable home and at risk of losing their children because of it.
Does this contradict my main statement to target providers before participants? No, it does not.
Mobility, incontinence and other disability supports all overpriced because NDIS pays for it – an attitude many will rub in disabled people’s faces “it’s not your money, it’s taxpayer money, you don’t own it”… “so give it to me” is the silent entitled attitude.
Cleaners $38/hr for the public and then $58/hr for NDIS – no change in services
Psychologist $170/hr and NDIS $232 plus notes
Sensory toys that are now no longer funded, were 2-2.5x the RRP and when it stopped being funded “massive clearance sales” that were still more than RRP at toy stores.
Lack of qualifications
Support Coordinators level 1 and 2 require NO QUALIFICATION, level 1 maximum (meaning what they all charge) is $80.06/hr and level 2 $100.14/hr
Create a qualification for this position, just like we have bookkeeping qualifications and childcare ones where we create policies, forms, reports and practice
implementing theory. Mandatory annual training and updates that are face to face so that participants don’t need to educate them.
Run a poll to see how many participants had their funds drained by a SC and them suffered through plan reviews on their own. My last one tried to bill something ridiculous like 10 hours for onboarding alone (for reference, onboarding is NOT billable, and most people get only 12 hours a year in SC funding). When I asked for exact breakdowns, she continued to be vague and eventually ceased services with me, then turned around and did an exit report filled with lies and opinions contradicting 4 professional opinions – and tried billing me another 2 hours for that. Oh, and did I mention it was right before an important requested review and she didn’t send me a copy because she knew I’d tell them it was lies and I had proof.
LAC and NDIS call center staff, planners half the time can’t give accurate or consistent advice. Not with regards to plans, what’s allowed under PAPL, what a plan can and cannot pay for, what treatments a person has to have tried for any given condition so that they can try them all. They tell participants to ask plan managers or the providers, when a participant calls to ask whether a provider can charge something… “hello, I’d like to know whether the provider trying to charge me this or that, can actually charge it” … “oh, well, you’ll have to call them and ask” … “I’m checking with you whether they are committing fraud and you’re telling me to call them” … “well yes, they would know”
Shall we take a look at all these wages and benefits, and what they cost the taxpayers?
Complex families support
Autistic people cannot live in paper thin houses, in autistic families, every person gets dysregulated from the noise. That garbage truck that may or may not wake you, sounds like it is smashing through their bedroom. The government needs to address this serious gap in housing ASAP, THAT is part of why there is such a rise in diagnosed cases.
Appropriate housing will reduce the co-morbidities in adulthood – BPD, OCD, PTSD, FND, fibromyalgia, etc.
Stop giving refugee visas PR and access to NDIS, before tossing off citizens
As I said, shift allied health onto MEDICARE, see how much it reduces the “blowout”
Each NDIS worker in any position and any structure, needs to register with NDIA, have an accessible file that confirms police checks etc
Thriving kids
My understanding is that this will manage autistic kids through school… what about the many who are homeschooled out of necessity?
Lastly, stop making it difficult for families to support their own people
The government takes taxes to redistribute in a “play god” method, there should be a sovereign wealth fund from profits of the country’s resources for those who need it.
Disabled and unemployed family members should be tax deductions for any of their family members, so that they can fairly survive at the tax rates they would have if each of them earned the money themselves. This used to be somewhat accomplished by trusts, but now that $55,000 distributed to a disabled family member is taxed at 30% instead of their individual actual effective rate of <10%
Forcing people to beg for scraps from the government.
I say again, this bill and many of the budget changes, are to destroy the low and middle income earners.