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  • Writer's pictureJacqui Grant

Where to next- post NDIS review announcements.








The pathway foward has been identified as a 5 year plan, it will take time!








This week has been huge for everyone who is involved in the disability sector, with more questions than answers right now. Many people are anxious and stressed. Providers are wondering if they will have ongoing work, some feeling they cannot afford to become NDIS registered, others are feeling they should race out and become registered.


People on NDIS plans worried about their future supports, each of these are very real and very releveant.


The one thing I will say is that the one choice WE all have is to choose whether we react to what has been release or whether we respond in accordance to the information provided.

Reactions are emotionally driven and whilst they are very important, and are to be respected and taken into account, for many people this is a business decision and therefore taking time to gatther all the information is important to make decisions.


In this article I am covering:


As someone who has 36 years of experience in health and disability and someone with extensive lived experience living with a disability, I have seen many changes over those years; some have been for the better, and some have been taking us backwards.


Before I go into listing the NDIS Review Recommendations, a little background of me and what has occurred in the past.


Pre-NDIS, we had hubs within the education schooling system for our children who required speech, physio and even occupational therapists to come and complete assessments and support the teachers, integration aides and parents. We were often bulk billed for services outside of the school, such as ongoing physiotherapy for my son; the neurologist and the Royal Children's Hospital were amazing with their support for us, especially families who had to travel over 3 hours to get the services for our children. These hubs were amazing and helped us so much. I ended up helping to coordinate those hubs and get them started in other rural centres and medium-sized towns.


The only support I had to assist me on the tough days with my children was my neighbours and friends, who had their family to care for; we couldn't get a support worker 24 years ago, so it fell onto the community.


These hubs that we used to have sound very much like the proposed foundational support services, that has been mentioned. There is a lot more information and services available now to what there was 24 years ago and we know a lot more, more diagnosis and treatment options.






Building Community can make a huge difference, potentially in a positive way!







Community and connection are something that I have included in every aspect of my business and it works in such an amazing and postive way. When I started to branch outside of that specific disability - NDIS to include in every masterclass and event I hosted for the past 15 months, people told me to stop doing that; however, I have always seen the benefits in community and connection, hence Connect and Grow magazine, podcast, expo's, events and coffee catch ups... building community.


Supporting each other is key to long term success for everyone.


The NDIS Review 26 Recommendations


The report is broken into four parts, and it's important to remember that all of this is RECOMMENDATIONS, and to date ( at the time of writing this 9th December 2023), there is no further information as to the next step or dates of when things will start to change, whilst it is all stressful and change can be hard right now it's important to have awareness and focus on what you can do right now.

Part 1: A uniformed system of support for people with a disability

Recommendations 1 - 9

Part 2: Markets and support systems that empower people with a disability

Recommendations 10 - 19

Part 3: Stewardess of the Unified Ecosystem

Recommendations 20 -23

Part 4: A five-year transition

Recommendations 24 - 26


You can read through each recommendation in the final review report in the link below.


What all of this means for everyone is that these are recommendations and whilst Mr Shorten has spoken about the top 7 at the recent press conference, there has been no date to when they are planning on implementing any of the recommendations.


The national cabinet on Wednesday also spoke about foundation support and more money to health and education to create this as being part of a 4 year plan,


There are several governing bodies that have to all get together and work out the next steps these include:

Australian Cabinet, National Cabinet, NDIS references, Australian Public Service committee, Disability reform minsteral council, Quality and Safeguard committee


Reference: All information obtained from the NDIS final review can be viewed here: NDIS Final Review Recommendations,

Easy to read version, which you can download


Many people with an NDIS plan are worried that when their plan comes up for review in 2 years time that they may lose their services and they may not be able to choose their providers, all completely understandable. Today all we can do is keep supporting them as best as we can.




For Providers moving forward


Registration is something that they have recommended for all providers to people with and NDIS plan.


I have had many people calling and messaging worried that they are going to have register now and many people saying they cannot afford the registration process, however we do not know the exact cost or how the registration process will be implemented.


If your business is set up correctly now to meet business compliance and Australian Consumer law, you will have a huge part of what is required for registration already in place, therefore any other costs will be less and we have to wait and see what exactly is required.


Here is what the NDIS review have recommended about that process and what it could potentially look like:


" Our proposed model (Figure 14) for the regulation of providers is based around four broad categories related to the risk associated with different types of supports and providers, with corresponding mandatory registration or enrolment requirements:

Advanced registration for all high-risk supports, applying more intensive regulatory requirements and oversight where supports may pose an inherently high-risk or require high-level technical competence. For example: Supports delivered in high-risk settings, such as daily living supports delivered in formal closed settings like group homes.

General registration for all medium-risk supports, applying graduated approaches to regulatory requirements and oversight, depending on factors impacting the level of risk. For example: High intensity supports (such as high intensity daily personal activities), supports that require additional skill and training (such as complex bowel care or injections), and supports involving significant 1:1 contact with people with disability.

Basic registration for all lower-risk supports, applying lighter-touch registration requirements, while still allowing for regulatory oversight against Practice Standards, when required.


For example: Sole traders and smaller organisations, supports such as social and community participation, and supports involving more limited 1:1 contact with people with disability.

Enrolment of all providers of lowest-risk supports, providing full visibility of the market and applying lightest-touch requirements through a simple online process. For example: Supports where general protections available under Australian Consumer Law are sufficient, such as consumables, equipment, technology, and home and vehicle modifications."


Figure 14: Graduated and risk-proportionate provider registration and enrolment

Provider obligations

 

A. Advanced registration


In-depth registration for high-risk supports

B. General registration


Graduated registration for medium-risk supports

C. Basic registration 


Light-touch registration for lower-risk supports

D. Enrolment Basic 


visibility and requirements for lowest-risk supports

Code of Conduct

YES

YES

YES

YES

Worker screening (Action 17.4)

YES


Workers in risk-assessed roles.

YES


Workers in risk-assessed roles.

YES


Workers in risk-assessed roles.

YES


Workers directly delivering specified supports or services, or who have more than incidental contact with people with disability.

Subject to complaints process

YES

YES

YES

YES

Report incidents

YES

YES

YES

NO

Practice Standards

YES


General standards for all support types and support-specific standards where needed.

YES


General standards for all support types and support-specific standards where needed.

YES


General standards for all support types and support-specific standards where needed.

YES


General standards for all support types and support-specific standards where needed.

Performance measurement (Action 12.3)

YES

YES

YES

NO

Processes

 

A. Advanced registration


In-depth registration for high-risk supports

B. General registration


Graduated registration for medium-risk supports

C. Basic registration 


Light-touch registration for lower-risk supports

D. Enrolment Basic 


visibility and requirements for lowest-risk supports

Application, identity verification and Code of Conduct and worker screening attestation

YES

  • Provider completes online application form, integrated with centralised online platform and NDIS payments system (Actions 10.1 and 10.3) to provide the NDIA and new National Disability Supports Quality and Safeguards Commission with visibility of all providers and data on payments.

  • Application form collects basic information (e.g. business name, ABN or Digital ID, bank account details, location, contact details, support types delivered).

  • Business identity is verified leveraging existing government systems and processes (such as myGovID).

  • Provider attests to understanding obligations under code of conduct and worker screening requirements.

 

A. Advanced registration


In-depth registration for high-risk supports

B. General registration


Graduated registration for medium-risk supports

C. Basic registration


Light-touch registration for lower-risk supports

D. Enrolment Basic


visibility and requirements for lowest-risk supports

Audit of compliance with Practice Standards

YES

  • In-depth observational audit of compliance with relevant practice standard.

  • Streamlining where appropriate based on risk, such as the use of desktop auditing, self-assessment and attestation, and mutual recognition of compliance in other regulatory systems.

YES

  • Graduated and proportionate audit of compliance with relevant practice standards, including observational and/or desktop auditing.

  • Streamlining where appropriate based on risk, such as the use of self-assessment and attestation, and mutual recognition of compliance in other regulatory systems.

NO


But includes a self assessment and attestation of compliance with Practice Standards, in place of an audit.

NO

Suitability assessment of provider and key personnel

YES

YES

YES

NO

 

A. Advanced registration


In-depth registration for high-risk supports

B. General registration


Graduated registration for medium-risk supports

C. Basic registration


Light-touch registration for lower-risk supports

D. Enrolment Basic


visibility and requirements for lowest-risk supports

Ongoing monitoring and compliance

YESThe National Disability Supports Commission undertakes:

  • Risk-based monitoring, investigation and regulatory intelligence gathering (including through provider outreach and information sharing with other regulators.

  • Corrective action in response to breaches of the code of conduct (registered and enrolled providers) and practice standards (registered providers only).





The key to remember is that many Sole traders, small companies will fall into the 3rd tier dependings on the services they are providing and choose to continue to provider. Every business will be different and there are many things to take into account.



The potentail cost, will overall it is important to remember that is to be formally announced, however if we were to look at it in comparrision to the current NDIS registration process the cost is:



  • Business set up - documents, policies and procedures

  • External Audit - these start at $1500 approximately for a paper based audit, where business' have no participants or staff, they then go up depending on the time it takes, the level of registration and this is determined by the size of the business.

  • Internal audit - this should only take a few hours depending on the size of your business ( we offer this services and discuss it with you, along with a gap analysis)

  • Business consultation/coaching - many make huge promises, promising ongoing support which never really occurs post audit ( we have sessions that suit you and do not ask you to sign up to long term commits, we also have courses to empower you at self paced learning - we work with you as you require it)

What can I do right now?





It starts with your business set up!





As a provider there are a couple of things you can do moving forward and preparing your business:


  • Review your current business plan and goals - adapt this as you feel you need to, taking into account the POTENTIAL impact if the recommendations are implemented.

  • Review your current business process. Are they inalignment with and meeting Australian Consumer Law and business compliance - separate to NDIS guidelines. If not, if you don;t have your documents, policies and procedures in place, now is the time to do that as you should have them in place now as part of business compliance in the disability, health sector.

  • Duty of care - review your business are you meeting all 4 levels of duty of care?

  • NDIS code of conduct. - Are you meeting and following the NDIS code of conduct as part of your business, if not what changes can you make?

  • Conflict of interest. Are you completely aware of any conflict of interest in your business and if there is a conflict of interest are you taking appropriate action to manage or remove it?

  • Risk and incident management system - do you have this in place, if not now now the time to do that. ( this forms part of your business process

  • Services your currently offer. If you are providing support coordination, recovery coaching and potentially plan management - yes there is a chance that this will change, if we go by the recommendations those roles potentially become the navigator, exactly how this will look from a functionality and business perspective does remain to be seen and there are many unanswered questions. I encourage you to read the recommendations of what the navigator looks like - remember the plan implementation has been set to 5 years.

  • Home and living - SIL, SDA - if you provide these services - recommendations have highlighted changes to how these will be monitored and once again it is a wait and see approach.

  • Types of services under NDIS will be reviewed. Evidence based services only - so if you are offering something that is not mainstream evidenced based and necessary for the person due to their disability, there is a POSSIBILITY those services will not be able to be paid for with NDIS funding in the future.


There are many meetings to be held, many discussion to occur by the relevant stakeholders and we are still to be told the date in which they are going to start implementing any of these review recommendations.


Frequently asked questions

I have been asked a lot of questions by both providers and participants and I am going to be sharing those in the December Connect and Grow Magazine, where more people can access them. I am still getting more questions in and also taking my time to research the right information and links, where possible. Some questions I cannot answer, as those answers are not clear yet.


One question I will answer right now:

"Should I get started on NDIS registration now?"

That is a business decision that only you can make for your business, (happy to go through your opitions with you during a coaching session) and based on the current registration requirements will help answer that. As above the new proposed registration process will be different for different service provider and therefore there is the potential that your business would not need to go through the current registration process. Whilst my answer is broad that is the best I can do right now. Take your time to look at all the provided information and make an informed decision on your business plan and financial plan.



Take care of you!


Take some time out for you, away from work, and be present in the moment.






Its important to take care of you and to take some time that is away from work and any stress all of this may be creating for you.


While I understand there is MORE questions than answers right now, make a note of your questions and where necessary please seek professional support, if you are finding the stress is too much, please see a counsellor to debrief and have a plan to manage your stress.


How we can Support you and your business


We are able to help you right now today:

The choices is all yours we have many FREE resources and information, along with paid services.

  • With your business process which includes your documents, policies and procedures - you can visit our Disability Sector store and look through the bundles - easy to use templates for your business.

  • Courses - we have a variety of courses for you and your business

  • Free initial call to discuss what you require. - book in here

  • Business Coaching - we work with you and do not ask you to sign up for long term coaching, unless you choose that, we would rather empower you and teach you.

  • Connect and Grow Magazine - articles that are available online, business advertising opportunities

  • Connect and Grow expo's and networking - building community to work together and support each other, 2024 dates announced soon. Online event is 14th December 2023 at 7pm

  • Connect and Grow Podcast - free to listen to at any time



Other related articles:



(C) 2023 Break Free Consultancy


Disclaimer: All information is accurate at the time of publication and is subject to change. It is general information and is intended as a guide only. For specific information for your specific situation, please consult with the correct person, by booking appointments with them. Reference links have been provided to where you the reader can access full articles. Always seek professional information from the relevant person - lawyer, Fairwork, Accountant and other releveant professionals.

The information in the article does NOT replace any professional information that you have sought.


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