Provider Tips

Allied health providers must review services for young participants to ensure they’re NDIS supports

David Kinnane · 10 October 2024 · Leave a Comment

The big picture:

Under new rules, allied health providers cannot be paid by the NDIA for services that are not ‘NDIS supports’.

Context:

‘NDIS supports’, as defined in the new section 10 of the NDIS Act 2013 and Schedule 1 of the NDIS (Getting the NDIS Back on Track No.1) (NDIS Supports) Transitional Rules 2024, include:

early intervention supports for early childhood (0-9 years) (Item 17); and
therapeutic supports (Item 34).

What to watch:

Allied health services must (of course) be evidence-based. In addition:

early intervention supports must help the child and their family achieve better long-term outcomes for the child (item 17); and
therapeutic supports must help participants improve or maintain their functional capacity (item 34).

What we’re doing:

We’re working with clients and families to review assessment, reporting, goal-setting, and therapy workflows to ensure our services are NDIS supports. To structure our review, we’re using the following frameworks:

Go deeper:

For more information about NDIS reforms, check out our free webinar.

Allied health providers: get up to speed on the key NDIS reforms that will affect your practice (a free resource)

David Kinnane · 2 October 2024 · Leave a Comment

Allied health providers: get up to speed!

NDIS reforms are accelerating (at least 10 announcements in the last month alone), and it’s hard to keep up while running a business. We’ve made a free video to help.

State of play:

Risks and opportunities
Key events and reforms
Potential implications

Sign up here:

Allied health NDIS providers: back yourself to try new things, and help more people: a case study

Paediatric allied health providers: let’s tackle our NDIS worries by improving our services, bit-by-bit, and monitoring general reform trends

The Government’s Draft List of Allied Health NDIS Supports: What’s In; and What’s Out

NDIS regulatory changes are coming. Allied health providers should stick together to advocate for choice and control

How will allied health NDIS providers survive? Some difficult choices ahead

Therapy Support Providers: Frozen pricing limits and shorter notice cancellation rules. What was the NDIA thinking?

The 1st Foundational Supports Consultation has kicked-off. 8 things allied health NDIS providers need to know

David Kinnane · 25 September 2024 · Leave a Comment

The Australian Government has kicked-off the consultation on Foundational Supports. As allied health NDIS providers, we’re following these developments closely because they have the potential to change our clients’ NDIS access and funding arrangements and, consequently, our service-delivery and general business models to support NDIS participants and others with disability.

On 20 September 2024, I attended a helpful webinar about one type of Foundational Supports called General Supports. I then reviewed the related General Supports Consultation Paper.

In this article, I’ll explain what the term “General Supports” means, and highlight my key takeaways for allied health providers from both the webinar and the consultation paper.

First, some context (because there is so much going on in the NDIS space!)

In 2023, the Independent Review into the NDIS recommended that governments fund and deliver foundational supports. They recommended that foundational supports would:

be additional supports to those delivered through the National Disability Insurance Scheme (NDIS) or through mainstream services; and
be available to all Australians with disability, whether they are NDIS participants or not; and
interconnect with existing mainstream services, like mainstream childcare and schools.

More specifically, the Review recommended governments deliver foundational supports for people with disability into two areas:

general supports to deliver access to trusted information and advice and build the capacity of all people with disability, including to fully participate in the community, and to make decisions and advocate on issues that impact them. General supports would also include information, advice and supports for families, carers and kin, and community organisations.
targeted supports to operate between inclusive mainstream services (for example in areas like early childhood, schools and community mental health) and the specialist supports accessed through the NDIS. These supports would focus on helping certain groups of people that are not accessing or not eligible for support that is delivered through the NDIS, in areas where the need is greatest.

In December 2023, National Cabinet agreed to design and jointly fund Foundational Supports, where appropriate, through existing services, with a view to phasing them in over time.

On 19 September 2024, the Government released their Disability Reform Roadmap for 2024 and 2025, stating that phased implementation of Foundational Supports will commence in 2025-2026. According to the consultation paper, the Australian Government expects that governments will agree a Foundational Support Strategy later this year (2024).

Key takeaways for allied health providers:

1. Narrow scope

For service delivery and business planning purposes, allied health providers are most focused on what targeted supports may entail in the delivery of our services within mainstream and community settings. However, the consultation paper and webinar cover only general supports, with the consultation paper focusing mainly on information, advice and capacity building supports for people with disability.

2. For many people with disability, the stakes and stress-levels are high

This was made clear when the webinar hosts shared the contact details for Lifeline.

In a vacuum, everyone might think that general supports are a good idea (and they are). But consultation on foundational supports is taking place in parallel with major legislative changes to the NDIS to restore “the original intent of the NDIS to support people with permanent and significant disability within a broader range of supports” (page 21). The reforms are also being carried out to ensure that the NDIS is financially sustainable, with implications for both existing and future NDIS participants.

The webinar hosts were adamant that:

the NDIS is here to stay;
foundational supports (including general supports) are additional supports so that the NDIS isn’t the only lifeboat in the ocean; and
any NDIS rule changes would not take effect until foundational supports are in place.

The consultation paper also makes it clear that accessing General Supports should not preclude someone from accessing the NDIS or other supports in the community (page 6).

But, with the new NDIS Amendment Act due to commence on 3 October 2024, some people are understandably worried that new “sustainability measures” (like the new concept of “NDIS support”) will reduce support for some participants before alternative supports can be put in place.

Time will tell.

3. People with disability should lead the design of General Supports

According to the consultation paper, general supports will include:

trusted information about disability, rights, and services;
supports and tools that build the skills, capacity and independence of individuals to make and sustain social networks and community connections, to make decisions (including supported decisions) and to advocate on issues that impact them;
information, advice and supports that empower and build the capacity of families, carers, and kin in supporting people with disability to participate and exercise choice and control over their own lives;
assistance to find and access mainstream, community or disability-specific services and activities appropriate to needs and goals;
information and advice that assist community organisations and non-government public services/activities to become more inclusive and responsive to the needs of people with disability (page 6).

Once implemented, these supports will be available nationally, will connect with other services, and tap into local community knowledge and networks.

As multiple webinar speakers noted, each person with disability is the expert on what they need, and what works for them. Discussions about accessibility and inclusion often include sweeping generalisations about what we think people with disability need, e.g. “more visual supports”. But, as Jane Britt, senior consultant and advisor of The Social Deck, highlighted, different people need different things. For example, someone who is deaf and blind is not going to be helped by visual supports or maps, and would – obviously – prefer information to be presented in a way they can access and understand. When encountering an obstacle to participation, a person with disability might need information about their rights and who to contact to enforce them.

It’s obvious, but needs to be said: different people have different needs and goals. But, as leading disability advocate Dr George Taleporos noted, common themes underpinning the consultation paper include empowering people to live independently and autonomously, to exercise choice and control, to live with dignity, to understand their rights, to self-advocate, and to participate, and to increase peer and other networks to to reduce isolation, and eliminate abuse and neglect.

Importantly, for allied health providers, people with disability should be able to access our services that are relevant to their needs and goals.

4. The design of General Supports will not start with a blank slate

A wide range of services and supports already exists, including the Information Linkages and Capacity Building (ILC) program, the Partners in the Community program, and the Disability Gateway.

For communities, workplaces, and schools who want to take action to be more inclusive, other resources are also available, e.g. via this helpful list of inclusion resources on the International Day of People with Disability website.

In the consultation paper, there’s not a lot of detail about the perceived deficiencies of the existing systems and resources. But it is apparent from the Independent Review recommendations, that, as things stand, we can do better. For example, the consultation paper writers note that, at present, “there are limited supports focused on early intervention, prevention or low intensity support needs for certain groups of people with disability that are not accessing or not eligible for support through the NDIS” (page 22).

General supports may include reforming some of these existing programs and services. But they are also likely to include additional programs beyond supports delivered through or in partnership with the NDIS.

5. Allied health providers shouldn’t wait to make their services more inclusive and accessible

As providers, we all need to work harder with people with disability (including our clients) to ensure our allied health services are inclusive and accessible to everyone, including people with disability and their families, carers and kin. We also need to understand the rights of people with disability; and to train our staff so that they understand people’s disability rights, too.

If we have knowledge gaps, we need to educate ourselves about the rights of people with disability. We should also share resources and best practices with each other to avoid reinventing wheels.

General supports may help us to do this. But lots of good information and resources exist to improve our understanding of disability rights and to get good ideas to improve the accessibility of our services (including here and here and here).

We all have a role to play in helping people with disability to access the allied health services they need, when they need them, and in a way that:

works for them;
respects their legal rights; and
reflects their goals.

This includes:

providing people with disability and others with accessible information about our team and services. We may need to provide this information in multiple ways, e.g. on our websites, via digital apps, through online chat and phone services, with links to quality information and resources about disability and childhood development relevant to our clients and services (see, e.g., page 9);
increasing our focus on providing services within local community settings to help build the capacity of community organisations like sports groups and arts groups to support people with disability (see, e.g., page 13); and
connecting people with disability to trustworthy information, tools, resources and other services as general supports progressively roll out.

We can all improve accessibility, and we can start work now. As allied health providers, we should lead the way by example.

6. Help your team get up to speed on core concepts

Appendix A of the consultation paper (pages 17-23) includes a very helpful glossary of terms relevant to Foundational Supports and the NDIS. While most allied health providers will be familiar with most terms, it’s a potentially helpful tool for training staff. It’s also a helpful reminder that we all need to be mindful of the language we use, even when fiercely debating the pros and cons of potential reforms.

7. Caveat: everything is subject to intergovernmental agreement

Page 3 of the consultation paper includes an important note for service providers:

“Any future funding opportunities will be promoted via normal procurement/commissioning and grant round mechanisms and will take into account transitional arrangements associated with reforms to existing programs. As the concepts in this paper have not yet been agreed by governments, they have no status within the provider market and should not be relied upon.” (Our emphasis.)

8. Get involved!

The consultation period closes on 30 November 2024. This is the first consultation on Foundational Supports, and may have knock-on effects to consultations for other supports, including Targeted Supports. You can give feedback in lots of ways, including via the DSS Engage website and/or by filling in an online questionnaire.

Key source:

Foundational Supports | engage.dss.gov.au

Our related articles:

Will NDIS reforms and foundational supports trigger the end for many paediatric allied health clinics?

NDIS “ins and outs” for participants seeking “mixed” disability, health and education supports: mind the gaps between NDIS and mainstream services

Paediatric allied health providers: let’s tackle our NDIS worries by improving our services, bit-by-bit, and monitoring general reform trends

Our new and updated NDIS provider resources:

NDIS Provider Human Resource Management System and Registers (HR System) Template

NDIS Worker Screening Policy and Risk Management Plan Template

NDIS Service Agreement Template 2024-25

Allied health NDIS providers: back yourself to try new things, and help more people: a case study

David Kinnane · 20 September 2024 · Leave a Comment

Experts tell us that constraints are good for innovation. If this is true, all the constraints imposed on allied health providers during 2024 should trigger an earthquake of innovation in our sector.

Although painful, this could be a good thing for providers, participants, other clients, and families. But…

Innovation is such a terrible buzzword!

Even typing the word made me cringe, with flashbacks to my corporate law days. And innovation in healthcare is poorly understood. As John Glaser taught me many years ago:

innovation doesn’t require us to invent stuff: Most allied health providers lack the time, money, and energy to create a pipeline of inventions. But that’s OK: there are plenty of other people’s inventions waiting for allied health providers to adapt them for our purposes;
innovation doesn’t require radical changes: Continuous, incremental service tweaks make more sense in uncertain times like now. Over time, they can compound to deliver big improvements for participant care; and
innovation isn’t a goal in itself. Innovation only makes sense if it contributes to our purpose.

So, how should we go about doing it in the real world?

Here’s a little case study to show you how we’re trying to do it in our practice:

1. Go back to the mission

Sometimes, as I pore over government press releases, consultation papers, expert reports, white papers, guides, and social media think pieces, I forget that navigating NDIS reforms isn’t actually my job.

I’m a speech pathologist running a single-site, independent clinic in Sydney. I started Banter Speech & Language more than 10 years ago to help children and adults with neurodevelopmental disorders and disabilities.

My special interest is helping people with significant communication challenges to speak, read, and write for themselves. My practice exists because I want to support clients to pursue their interests; and to participate fully at school, work, and out in the community – just like everyone else.

Six days a week, my wonderful team works hard to deliver quality, evidence-based support to clients in the clinic and by telehealth, including NDIS participants.

But we have a problem.

2. Identify something specific that’s getting in the way of the mission

Every workday, we field queries from all over Australia and overseas from families with children with disabilities who are struggling to access the help they need when they need it.

Many obstacles to access aren’t new. Mainstream education and health support for children with neurodevelopmental disorders and disability remains patchy. Too often, the NDIS is the only way for children to access help. In the real world, NDIS access and funding rules favour some children over others. (Different diagnoses, postcodes, and abilities to navigate “the system” mean that different children with similar functional needs get very different levels of support.) Because of disability, many children have health, education, and disability needs; but health, education and disability systems operate independently, with uneven levels of support depending on where they live. (This is one of the main problems underpinning the government’s decision to move forward on Foundational Supports.)

As a small provider, these systemic problems seem insurmountable, and far too abstract to do anything about. To avoid paralysis, we need to:

3. Get more specific until we find a concrete problem

Here’s an example. For privately-funded families, we deliver evidence-informed writing interventions for students with neurodevelopmental disorders, including autism, developmental speech sound disorders, developmental language disorder, specific learning disorders in reading and writing (better known as dyslexia and dysgraphia), and ADHD.

Writing instruction is considered a “mainstream educational service”, and thus outside the NDIS (including under the proposed transitional rules). But, for students with disabilities, an inability to write is also a health and disability issue that interacts with their primary speech, oral language and social communication difficulties to reduce participation.

Literacy improves work, health, and life outcomes. And writing is an essential part of literacy. Learning to write gives children a big boost at school, and later at work and in life. Writing helps children to remember things; to connect their day-to-day thoughts to their goals and plans; to communicate what’s going on to their friends, family, teachers and employers; to share and develop their ideas with others; and to think and advocate for themselves independently.

So, writing interventions create many challenges for our families and team. They are:

in high demand by many families, including families of children with disability;
unfunded by the NDIS, meaning many children across the country simply can’t access any help;
time-consuming: most of our clients have lots of other challenges, too, including with their speech, oral language, and social communication skills;
expensive to deliver: many clients with disability need lots of direct teaching, modelling, repetition, scaffolding and spaced practice to master foundational writing skills; and
not carried out in the child’s “real-world”, e.g. at home or school.

To complicate matters, post-COVID, we started to be approached by lots of parents who were keen to help their reluctant writers overcome their writing challenges, including children in mainstream education settings; and children who were not in a mainstream school system (including home-schooled students). We wanted to help. But this spike in demand created havoc with our waiting lists.

But, despite all these challenges, we know that early writing interventions can make a big difference for short-term academic and social participation and longer-term work, health and life outcomes.

4. Be brave. Try and test new ideas

All these events and observations gave us the idea and motivation to launch Rally Writers.

It’s an online project to increase access to writing help for children. It’s for school-aged children – with and without disability – who need extra support with their writing for any reason. It’s self-paced, and can be worked through in natural settings like home or at school, one-to-one or in small groups, with or without an adult in the room.

Rally Writers is a labour of love that I work on during weekends and evenings. It’s designed to be affordable, not dependent on NDIS-funding, and suitable for children and teenagers.

To date, we’ve released three modules (or “Cups”): for simple, compound and complex sentence writing. (We see far too many children and teens who can’t write complete sentences.)

Start Your Engines: How to Write Simple Sentences

I’ve written five additional modules: for writing paragraphs, information reports, narratives, persuasive writing foundations, and advanced persuasive texts, which will be released progressively over the next year or so (when I find time to record them!).

For existing clients with disability, we can now spend our time in sessions on speech, oral language and social communication goals, and provide free access to our Rally Writers resources so they can work on writing at home.

If you are interested in the project, you can check it out here:

Rally Writers: we help reluctant writers

5. Stay open to feedback (including from other colleagues and other providers!)

Rally Writers is an example of a small, controlled experiment, adapting existing technologies to increase access and decrease costs in pursuit of our mission.

As part of the project, we’re actively seeking client and other feedback to make it better as we go. We expect it will undergo several iterations as we incorporate suggestions and get better at using technology.

If you have thoughts about Rally Writers, or this little case study, please get in touch!

Paediatric allied health providers: let’s tackle our NDIS worries by improving our services, bit-by-bit, and monitoring general reform trends

David Kinnane · 12 September 2024 · Leave a Comment

Many paediatric allied health providers are taking a wait and see approach with NDIS reforms.

We get it.

In just the last few months, we’ve faced:

disappointing news about frozen pricing limits;
the sudden passing of the new NDIS Amendment (Getting the NDIS Back on Track No.1) Act, which will will come into effect on 3 October 2024, with many new rules to come;
a very short consultation about proposed transitional rules around “in and outs” for NDIS supports;
conjecture about whether registration will become mandatory and, if so, whether existing professional registrations and certifications will suffice;
uncertainty around the implications of a new Foundational Supports regime; and
sometimes unfair media and social media criticism, including wild generalisations about the motives and ethics of providers based on the poor behaviours of a few bad apples.

All this VUCA – volatility, uncertainty, complexity and ambiguity – can be paralysing. And it’s not as if we have a lot of spare time to ponder or plan for it all while supporting participants, families, and staff through difficult business conditions.

But, even if you’re not up for a full service delivery review right now, there are plenty of small things we can do – or at least start – to improve participant safety and service quality for the people who matter most: participants and their families.

A. Taking small, positive actions can increase your sense of control in uncertain times and improve our care and services

Here are some simple quality improvement ideas we’ve extracted from the NDIS Quality and Safeguards Commission’s recent Quality support for children guide:

Improve families’ confidence in your team

Ensure your register of Working With Children Checks on all staff is complete and up to date.
Even if you are an unregistered NDIS provider, have your team complete NDIS Worker Screening Checks. (It seems likely these checks will become mandatory for most staff who interact with people with a disability.)
For each of your professional staff, run annual checks of the AHPRA registration and/or membership status with the NASRHP member peak bodies (as appropriate).
Double check the currency and adequacy of your professional indemnity insurances and the status of insurance arrangements for each professional staff member.
Train all staff, in detail, on the NDIS Code of Conduct and remind staff they must abide by it. (This Code applies to both registered and unregistered providers.)
Consider incorporating the NDIS Code of Conduct and professional Ethics Code requirements into your existing organisational Code of Conduct so the key expectations are set out in one place.
Review the NDIS Early Childhood Support Standards for early childhood support. (Although these apply to registered providers, there is no reason quality unregistered providers shouldn’t understand and comply with them.)

Improve client decision-making supports

Train (or refresher train) your staff to communicate with children in a range of ways that clients prefer, including through the use of assistive technology, augmented and alternative communication, and visual supports.
Review the strategies and set-ups you use to support children to feel safe and calm in your workplaces.
Think about how you can better support children to speak up when they are unhappy, uncomfortable or feel unsafe when working with your practice.

Enhance client privacy and dignity

Review spaces for safety and ensure confidential conversations happen in private spaces.
Review and communicate your privacy policy and confidentiality arrangements to families in an accessible way.
Always ask for consent to share information with others and remember that consent can be withdrawn.

Improve client safety

In addition to Working With Children Checks and NDIS Worker Screening clearances, make sure staff are trained at least annually in CPR/first aid.
Institute a plain English Incident Management System. (For unregistered providers, benchmark the policy to requirements of the NDIS rules.)
Make sure your team members are trained about the laws relating to restrictive practices as they apply to your supports and practices.
Review your emergency and disaster management procedures. (For unregistered providers, benchmark them to the standards required of registered providers.)

Improve transparency around competence

Review and explain to families the scope of services you provide (and don’t provide), your qualifications to provide them, the associated costs, risks and benefits, and the expected timeline for supports.
Increase the transparency of your disclosures to clients around staff qualifications and experience.
Explain staff supervision and training arrangements to clients (and the public).
Review and update your referral policies for when the services sought are outside of qualifications and experience. (Make sure there are no secret commissions or conflicts.)
Review your Complaints Management System Policy. (For unregistered providers, benchmark it to the level required of registered providers under the NDIS rules.)

Improve the integrity, honesty and transparency marketing materials

Review your marketing materials to ensure they are up-to-date, accurate and honest.
Be clear about what families can expect and your terms of service: the who, what when, where, why and how much.
Train your team to ensure that no one engages in “hard selling” practices or plays on family fears, e.g. around service scarcity and waitlists.
Review the accessibility of consent forms and processes to make sure they are understood.
Restate how you manage and avoid potential conflicts of interest.
Increase the quality of your written reports, based on evidence-based assessments, that can be shared with families and other professionals working with clients.
Do what you say you will do in a timely way – including revisiting policies on your timeframes for reports.

B. All too much right now? At least keep your eye on these 7 bigger themes

If you’re still intent on a ‘wait and see’ approach, at least pay attention to key themes underpinning many of the proposed reforms. Watch the following general trends because they are likely to affect your business planning and service delivery models in the longer term:

A focus on providers working more collaboratively with the family and the rest of the client’s support team – not in isolation – including with regular team meetings.
An emphasis on using evidence-based functional assessment tools to measure baselines and progress more rigorously.
More focus on goal-setting with families, skills measurements, and outcomes that promote increased participation.
A general preference for delivering supports in homes, in the community, and in education settings.
More direction to providers to:
- provide strategies and tools that enable young children to take part in play, daily activities and routines (rather than doing therapy at the expense of play, rest and social opportunities); and
- coach family members, educators, and support workers to use evidence-based strategies in real world situations.
An expectation that providers will honestly and transparently:
- discuss supports that are unlikely to be funded by the NDIS; and
- help families find other ways to get help, e.g. through mainstream or community services.
A policy objective of reducing conflicts of interests and duplication of functions as part of proposed transition to “navigators”.

Bottom line

In the short term, allied health NDIS providers – including sole traders – should take small, incremental actions to ward off fears about the future of the NDIS, and increase service quality and safety standards and to improve our supports for participants and their families.

We should also start thinking about strategies to build tighter collaborative networks with other providers, deliver more services in home, school and community settings, increase the rigour of functional assessments and outcome measures, and, ultimately, eliminate over-reliance on NDIS-funding to secure our long-term success.