Submission to NDIA on 2016 Pricing Review

Since rollout of the NDIS commenced in launch sites, mental health providers have raised concerns about the match between the hourly prices paid by the NDIA for psychosocial support work and the reality of delivering that work by suitably qualified personnel. Some providers have described their work in launch sites as ‘loss-leading’, undertaken under the assumption that it will be eventually become apparent to the NDIA that its pricing structures need revisiting, and acknowledging that this one of a myriad of implementation challenges.

Less optimistically, some mental health providers envisage a ‘race to the bottom’, where a less skilled workforce becomes a competitive advantage and choice for participants is eroded over time, as providers become unable to support more highly trained workers under the terms set by the NDIA.

Mental Health Australia is eager to assist the NDIA to learn more about the key cost drivers within the business model for mental health providers.

With these different scenarios in mind, it is encouraging to note the NDIA’s observation that “if price limits were set too low, providers would be unable to recover even efficient costs. This could result in a significant share of providers leaving the sector and/or a lack of new investment in disability services.”

Mental Health Australia recommended:

  • that the NDIA gives further consideration to strategies that would identify the types of organisations most at risk, mitigates against these very real risks, and discusses these strategies with stakeholders as the market for disability services evolves.
  • the NDIA engages in an ongoing dialogue with providers about the current assumptions in the model. This will support more detailed, and thorough consultation processes in the future, and build the NDIA’s evidence base.
  • that the NDIA monitors the use of support coordination items (at each of the three levels) in plans relative to other support items, including but not limited to personal support and community participation, for participants with psychosocial disability.
  • that the NDIA investigates how its pricing models can incorporate the costs of innovation, co-ordination with other service providers, ICT investments and other inputs that are not explicitly supported through an hourly unit price, but which nonetheless affect long-term viability in the NDIS marketplace.
  • that the NDIA considers the best way of ensuring participants from linguistically diverse backgrounds are able to access TIS services as required.
  • that the NDIA closely considers the recommendations of the Productivity Commission’s report on the contribution of the non-profit sector to ensure that it does not repeat the well-documented mistakes of other government agencies in its commissioning task.
  • that the NDIA conducts a price review on training, supervision and support. • that mechanisms be developed so that it is financially viable for participants to choose to have all of their support from the same person.
  • that the NDIA conduct a review on how NDIS pricing structures impact on care needs outside of the NDIS.
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