Novita’s experience with the NDIS planning system

05 September 2019

Joint Standing Committee on the

National Disability Insurance Scheme

PO Box 6100

Parliament House

Canberra ACT 2600

ndis.sen@aph.gov.au

Committee Members,

THE JOINT STANDING COMMITTEE ON THE NATIONAL DISABILITY INSURANCE SCHEME

SUBMISSION: NDIS PLANNING

We thank you for the opportunity to provide input into this inquiry that aims to review the implementation, performance and governance of the National Disability Insurance Scheme (NDIS). In particular, this submission focuses on the experience of Novita and our many clients and families in relation to the NDIS planning system.

Novita has a unique experience of working within the NDIS framework due to our high concentration on the early childhood years and the nature of the trial site roll out in South Australia which commenced in

By the end of the trial period, Novita had largely transitioned to the NDIS before most organisations in Australia had commenced operating in the scheme.

Our transition to the NDIS has been a particularly challenging journey as we endeavoured to invest in the systems, services and culture required while at the same time navigating the challenges of the scheme implementation.

Novita’s experience in transitioning to the scheme and now operating at volume has provided valuable insight into the NDIS planning system which we hope will be of assistance in this inquiry.

ABOUT NOVITA

Novita (Formerly the Crippled Children’s Association of South Australia) has been operating for more than 80 years and provides services to more than 3200 children, young people and adults with a disability. Novita employs more than 500 staff and submits between 700-1000 NDIS claims each day.

We provide a range of services across both metropolitan and regional South Australia including:

Allied health therapy and family services;
Community programs including day options and specialist disability out of hours school care;
Supported independent living;
Assistive technology procurement, customisation and modifications; and
Individual supports. Based on the experience of our staff and the many clients and families we work with, Novita has observed the following issues in relation to the NDIS Planning system.

Planning General

•  The NDIS  plans  that  are  developed  are  inconsistent  amongst  participants.  These

inconsistencies span across the types of supports included and also the NDIS funds allocated, and appear to be highly dependent on the individual planner.

The skills, knowledge and experience of NDIS planners are also highly variable. In some cases, a lack of understanding of disability can lead to an inadequate plan or excessive requests for justification from participants and providers.
The information provided by planners to participants is highly inconsistent and dependent on the individual planners interpretation of NDIS policy and the price guide.
The ability of the NDIS or local areas coordinators (LAC) to keep up with the demand for plans has led to lengthy delays for many participants in accessing the scheme or having their plan reviewed or renewed.
The NDIS planning process often fails to take into account the complexities of service access in regional/remote communities. As a result the regional areas Novita operates within all feature low plan utilisation rates due to numerous constraints on how funds can be used to fund travel, or access specialist services in a thin market.

Assistive Technology

The planning system does not provide an efficient and responsive mechanism for the approval of critical assistive technology for NDIS participants. Novita has a range of participants who have been waiting 12-24 months for approval of assistive technology that has been prescribed by

skilled and experienced clinical staff. This equipment is often critical to the growth and

development of children and young people and delays risk amplifying support needs over time. Our technology team have observed a significant reduction in equipment outcomes compared with the previous State arrangements.

The overhead and costs associated with justifying assistive technology prescriptions are excessive and the process causes significant distress for both clients and staff. The cost of justification often far outweighs the cost of the item itself.

Planning Challenges

Plans are often not reviewed in a timely manner, meaning that a gap exists where both the participant and provider have no funds to draw on to pay for supports. These gaps can often last from three to six months and generate significant overhead cost to recover funds for services delivered during this time. Gaps also place significant cash flow challenges on providers who continue to deliver services during that period of time.
Novita data shows that the average plan length has reduced since the introduction of the scheme and with the lowest average plan length reaching approximately three months. Due to plan reviews, gap plans and shorter plans, the average service booking length is now at approximately 6 months. In general, the shorter the plan period is, the the greater the administrative complexity and more costly the system becomes for participants and providers.
While NDIS policy is still volatile and rapidly changing, the planning system is often out of step with NDIS policy changes to ensure that the funding and supports in plans reflects NDIS changes.
Providers do not have visibility of changes to NDIS plans that impact on existing service bookings, which creates a large administrative burden in maintaining the service booking system and managing the resultant billing errors.
In some instances, providers of Supported Independent Living appear to have significant control over the participant in the planning process and as a result, play a role in guiding the participant to greater reliance on SIL services at the expense of community supports aligned to their goals.
NDIS planners operate in accordance within internal NDIS communications and directives that are not visible to NDIS participants or providers, which contributes to inconsistent

communication and variability in the planning system.

RECOMMENDATIONS

Based on  these  experiences,  Novita recommends  the  following measures  to  improving  the

effectiveness of the planning system, and reducing inconsistency in the NDIS planning experience for participants and providers.

Introduce 2-3 year plans as the default to promote continuity of service for participants and providers. Such an approach will still enable plan reviews to take place as required to

accommodate changes in circumstances. Longer plans would be particularly relevant where a participant has a long term disability where needs are likely to remain constant over time or will run to a predictable timeline. Longer plans would also reduce administrative overheads and cost to the scheme.

Before finalising NDIS plans, the participant, their family and/or advocate should have a chance to review it to ensure that they understand the plan and also that the supports are adequate. Such a step would dramatically decrease the number of appeals, review requests and would improve outcomes for scheme participants.
In the case that a plan review does not occur in a timely manner, the NDIS plan should be automatically rolled over and indexed for a further 12 months to ensure continuity of service. This change should be clearly communicated with the participant and also any associated service providers.
Introduce mandatory disability awareness training and standardised mandatory knowledge requirements for all NDIS planners.
Produce a ‘plain english’ planning and price guide for use by planners, participants and providers to refer to collectively as a single source of truth. Such a guide should include how the planning system works, what supports are funded, what rates apply and how specific policies should be interpreted and implemented.
Introduce participant safeguards to ensure that the NDIS planning process is not unduly controlled by SIL providers and that any conflict of interest is managed.
Assistive technology should be processed and approved within specified minimum timeframes. Where assistive technology is a direct replacement or upgrades for an existing item, the process should be streamlined. Plans should also include funds for ongoing maintenance and repairs as required.
Where the NDIS introduces significant policy changes, such as changes to rates and changes to the scope of funded services, NDIS plans should be automatically increased to ensure continuity for participants and service providers.
The MM region classifications should not be the only factor determining NDIS prices related to travel in regional areas. Areas identified as ‘thin markets’ should be considered as having unique characteristics that may require a range of ‘travel’ and ‘service delivery’ options for NDIS participants.
The introduction of a notification/alert system for participants and providers regarding any changes to NDIS plans would significantly reduce booking uncertainty and billing issues. This could be achieved through the introduction of an application program interface (API) that would support the electronic exchange of data between providers and the NDIS.

Thank you for the opportunity to share our insights into the NDIS planning system. If you require any further information or clarification, please don’t hesitate to contact me on .

Yours sincerely,