About Integra
Integrated Care Pty Ltd (trading as Integra) is a privately owned, nationally registered provider of supports under the National Disability Insurance Scheme.
Integra enjoys a national perspective on the operation of the NDIS through its service footprint. Integra supports thousands of Participants every day, in every state and territory of Australia, to exercise choice and control through Plan Management and Support Coordination.
We have deep and specific expertise and purpose built systems related to Plan Management and Support Coordination that have been developed specifically to meet the needs of Participants, Providers, Support Coordinators and other Stakeholders.
Integra has made substantial investment at its own cost and our Plan Management service is highly automated and is supported by expert customer service staff with purpose built systems, deep knowledge and understanding of the NDIS pricing and supports and how Participants and Providers, and the NDIA and its commissioned services interpret and interact with these requirements and processes.
Integra’s Support Coordination service is provided to hundreds of Australians to connect with supports to achieve their goals. Integra’s Support Coordinators play an important role and have a firsthand perspective on the planning process across jurisdictions.
About Julie Keene, CEO Integra
Julie Keene is the Chief Executive Officer of Integra and is the Chair of Disability Intermediaries Australia. Julie has held senior executive roles within the health, higher education and financial services sectors over more than 25 years. Prior to Integra, Julie served as the Chief Financial Officer
at HBF Health, the Executive Director Finance, Planning and Commercial Services at Murdoch
University and has held board roles in the community services, health, education and tourism sectors.
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Integra’s key issues for Committee consideration
Integra notes the current NDIS planning process whereby a Local Area Coordinator (LAC) undertakes a Plan Review and submits to a NDIA Planner or delegate in many instances leads to:
- Double handling of the plan
- Increased wait times for Participants and other stakeholders
- Negative impacts due to lack of expertise of, and/or lack of access to relevant information by, Local Area Coordinators (LACs).
Integra supports a move towards dedicated NDIA planners as the norm to improve timeframes, increase overall consistency of experiences and outcomes for stakeholders, and reduce duplication.
Integra has provided comments on individual Terms of Reference, and in relevant areas made recommendations for the Committee’s consideration.
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Integra response to Joint Standing Committee Terms of Reference
We have reviewed the Terms of Reference and provide the following for your consideration:
a. the experience, expertise and qualifications of planners; Integra notes there is a lack of understanding of Plan Management among planners and Local Area Coordinators (LACs), which results in inconsistent Participant understanding and outcomes.
Planners and LACs appear to not understand:
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That Plan Management is not a ‘reasonable and necessary’ consideration. When plan management is requested, it is not subject to a reasonable and necessary decision.
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When Plan Management is requested, there is no requirement to justify the request, or that it is “needed”. It can’t be denied except in extraordinary circumstances
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Plan Management fees do not reduce other support budgets. The participant gets more help, more choice for no additional cost to their other supports.
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Participants do not necessarily benefit from going to a disability specific Plan Manager. Plan Management is a specialist skill in itself that can cover all disability types.
In relation to Support Coordination, Integra’s Support Coordination team has firsthand experience of the wide range of competency of planners and Local Area Coordinators, across States and Territories. The consistency and ability of planners to support participants appears to remain challenged. Problems are exacerbated by the workload related to the processing of new plans, and reviewing existing plans, as well as the other elements of a LAC role which also include community development tasks related to the broader needs of people with a disability. Specialisation of the Planning role would deliver improved experiences and outcomes for all stakeholders.
Integra recommendation 1 – to better support consistency of experiences and outcomes for stakeholders, that the Committee recommend the implementation of:
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a standard baseline of requirements for Planners and Local Area Coordinators supported by an integrated system of reference packaging.
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Administration of, and access to, consistent process and planning tools.
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Separation and clarity on the Planning and LAC roles.
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A separate workforce recruited to undertake community development. b. the ability of planners to understand and address complex needs; Integra understands there is a wide range of complex needs that are required to be addressed in the planning process. Integra is aware that some Planners and LACs do not possess the relevant knowledge or access to information for specific or complex or multiple disabilities, resulting in negative outcomes for Participants and families.
The current framework for Planners provides a basis for addressing complex needs, however the LAC community does not appear to have access to this expertise.
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Integra Recommendation 2 – that the Committee recommend:
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the NDIA develop a database to support understanding of complex, rare, multiple disabilities.
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the allocation of more experienced Planners and LACs where potential issues are identified that may lead to negative outcomes without additional expertise.
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LACs be given access to the current level of expertise already within the NDIA. c. the ongoing training and professional development of planners; Integra supports the ongoing development of planners to understand and communicate Plan Management as an option for NDIS Participants. Plan Management is an option available to all and is not subject to a Reasonable and Necessary decision.
At present, the understanding of Plan Management by planners and Local Area Coordinators is not consistent, for example, some planners do not understand that Plan Management enables a Participant to source an unregistered provider to deliver supports. This is a critical matter for Participants in a wide range of scenarios including those who live in areas where there are less registered providers, and for those who seek greater choice and control without the burden of administration, or the cost of covering purchases when necessary (for those who self manage). Integra supports the ongoing development of planners to better understand and respond to the needs and aspirations of NDIS Participants.
Integra is also a member of Disability Intermediaries Australia (DIA), a peak body for NDIS Intermediary services who provide Plan Management and Support Coordination services. DIA is an active voice for positive reform of NDIS and has indicated its willingness to work with the National Disability Insurance Agency to produce better outcomes including the planning process and support for planners.
Integra recommendation 3 – Integra supports the development of an improved education process, including around Plan Management options, including the development of ‘Service Guides’ that include information regarding different disabilities, a baseline of information and understanding of Plan Management and Support Coordination requirements and expectations for all stakeholders. Integra would be willing to assist directly or as a member of DIA.
d. the overall number of planners relative to the demand for plans; Integra is not privy to the number of planners and their individual workloads in terms of NDIS plans. Integra notes approximately 2,500 NDIS plans are being approved each week, and that there are around 300,000 NDIS participants with active plans as at end June 2019.
Integra notes that in some cases, delays in timeframes for NDIS plan meetings and reviews can have a significant impact on supports and the Participant’s independence while they wait for a meeting date, and contribute to an unnecessary level of invoicing and payment rejections caused by subsequent plan exhaustion or suspension.
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e. participant involvement in planning processes and the efficacy of introducing draft plans; Integra understands the main intent of draft Plans is to make the planning process more easily understood, more efficient and helps minimise time delays. We understand the planned approach is that a draft Plan is presented at the planning meeting and assists discussion and agreement.
Integra supports Participants and their families and representatives having consistent access to relevant advice and support prior to, and at, the planning meetings to choose Plan Management as an option.
Participants report to Integra they are often not aware of, or understand they must ask for, this option, and worse, they are often not advised this option exists at all, which limits choice and control. Integra would support a clearer and more transparent advice to Participants and Planners about Plan Management. This includes some Providers, who often push Agency Management to a Participant who is then not fully aware of the limitations this may have on their ability to exercise choice and control.
Integra recommendation 4 – That the Committee recommends the NDIA develop stronger and clearer advice for Participants within the Planning process, so they are aware of, and understand, their options and what they must do to take advantage of any option, including the Plan Management option.
f. the incidence, severity and impact of plan gaps; Plan gaps result in a range of negative outcomes for Participants and Providers including lost support opportunities for Participants, increased Accounts Receivable, and lost revenue for Providers. Integra is managing more than $320,000 each day in NDIS payments, and less than 1% of payments are impacted by plan gaps. However, a significant amount of work is required to resolve these issues. Participants and Providers often mistakenly single out Plan Managers as being responsible for issues arising from Plan gaps, including being unable to process invoices for services which occur during the plan gap and this creates an unfair perception that negatively impacts our business and employees. Accordingly, Integra supports the introduction of measures which enable stakeholders to be notified of a plan gap, or better, for there to be provision for interim extension of the existing plan to apply.
Plan gaps impact the set up of Participant activities in line with their goals and funded supports, and increases the workload of Support Coordinators when Providers indicate they will not provide services during the Plan gap. We support an interim arrangement applying to ensure services and supports can be maintained for Participants. In cases where a plan no longer includes Support Coordination, we support an alert being issued to the current Support Coordinator so that relevant arrangements can be made or altered.
g. the reassessment process, including the incidence and impact of funding changes; Changes to NDIS plans resulting from reassessment results in increased administration for Plan Managers and the need to trouble shoot issues directly with providers for issues that arise as a result of NDIA decisions. Integra is paid a small set-up fee for 12 month NDIS plans (ranging from $227.53
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non remote, $318.54 remote and $341.30 very remote), not in parity with the amount of work associated with resolving multiple parties including Participants and their representatives, Providers and the NDIA. Potential loss of this annual amount will place added pressure on Plan Management organisations such as Integra who are investing in innovation to deliver all stakeholders greater utility when it comes to understanding, accessing and using NDIS plans.
Funding changes also cause confusion and increased Accounts Payable for Plan Managers. We would prefer this could be dealt with in the back end of the system.
About 30% of Participants lose Support Coordination after 2 to 3 years. Support Coordination is critical for a large number of Participants to exercise choice and control over their NDIS plans and in accessing supports. We note there is substantial variation across jurisdictions in relation to Support Coordination, the reasons for which may be associated with the varying levels of understanding and awareness of Planners and LACs. We note also some Participants receiving Support Coordination find that they cease receiving Support Coordination during reassessment.
h. the review process and means to streamline it; Integra supports all efforts to streamline the NDIS processes including reviews, to make it easier for Participants and other stakeholders to deliver greater social and economic participation for NDIS Participants.
Integra notes there are opportunities for better communication by the NDIA and Planners as to when reviews are occurring, to help prevent rejections. Integra further notes Plan Managers are paid a relatively small fee for the establishment of a plan management arrangement for a NDIS Participant, and that the Australian Government is working towards longer plan periods.
Integra commends recent changes that came into effect 1 July 2019 that enable Support Coordinators to better support Participants through the Plan review process.
Integra supports greater certainty and the ability to plan for longer term, and we note that there should be specific consideration of the impact on Plan Management organisations and our ongoing ability to invest in our systems and staff to deliver best practice Plan Management including digital and online platforms, with access to expert contact centre staff. We are also considering the economic feasibility of providing extended contact centre hours as well as the introduction of video conferencing which also involves human and technological costs that may be unfeasible if the current Plan Management funding is not increased, let alone reduced. Integra urges the Committee to understand and comment on the impact of extended NDIS plan periods on Plan Management services.
Integra recommendation 5 – Integra requests the Committee carefully consider the impact of changes to the planning process on Plan Management, including on any changes to revenue that may negatively impact ongoing sustainability and innovation of this support.
i. the incidence of appeals to the AAT and possible measures to reduce the number; Integra notes appeals to the AAT and other jurisdictions in relation to NDIS often result in changes to what may be accepted as able to be paid through NDIS funded plans. This in turn results in added
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work for Integra, including system changes, staff training and resolution activities with stakeholders which is not factored into NDIA pricing.
j. the circumstances in which plans could be automatically rolled-over; Integra understands Plan rollovers will have benefits for many stakeholders but requests the Committee consider unintended impacts including negative impacts on the revenue of providers and their consequent ability to invest in continued innovation.
Integra further notes the issue of underutilisation is prevalent across NDIS plans, and negatively impacts a range of stakeholders. One potential impact of a Plan rollover may be to entrench a negative outcome where a Participant has not fully utilised their plan, including for reasons beyond their control such as Provider availability, illness, accident, other personal circumstances.
Integra recommendation 6 – That before any change is adopted or implemented, further analysis is undertaken to better understand:
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the impact of Plan rollovers for Participants whose disability is subject to change, or where significant life transition points are known to lead to changes in needs.
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revenue impact for providers of Plan Management of the introduction of Plan rollovers (ie the annual set up fee), including a reduced ability to continue innovating and value adding for stakeholders.
k. the circumstances in which longer plans could be introduced; Integra understands Plan rollovers will have benefits for many stakeholders but requests the Committee consider unintended impacts including negative impacts on the revenue of Plan Management providers.
Integra recommendation 6 – That the committee:
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Recommends Participants could have the option of choosing plans of various length, with the option of requesting a review.
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Report on the range of impacts of longer Plans on Participants, Support categories as well as the revenue of providers of Plan Management if a plan set up fee (currently predominantly annual plan) is removed.
l. the adequacy of the planning process for rural and regional participants; and Integra provides Plan Management for NDIS Participants in every state and territory in Australia, including people living in remote and very remote areas. Access to suitably supported and qualified Planners and Local Area Coordinators in regional and remote areas is an ongoing issue for people with disability and their families, consistent with other supply issues in the disability sector.
Integra supports improvements for Australians in regional and remote areas in participating in the development of their NDIS plans with suitably qualified staff, and in being able to access support and
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advice to do so. Integra is investing in its technology to help support Australians to fully participate in and exercise choice and control in relation to their NDIS plans.
m. any other related matters. Integra is aware of the Light Touch Plan Review as an option for Participants to request minor changes to plans, however this is not widely or consistently known.
Integra recommendation 7 - When a plan is incorrectly set up (or a Participant just wants to change how a plan is managed), then a ‘Light Touch Plan Review’ should be quick, easy and widely known as an option.
Thank you for the opportunity to provide our views on the NDIS Planning process. We wish you well in your deliberations.
Integra Plan Management
P 1800 69 63 47 E choiceandcontrol@myintegra.com.au W http://myintegra.com.au
Integra Support Coordination
P 1300 937 187 E enquiries@myintegra.com.au W http://myintegra.com.au
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