early intervention supports

What’s happened?

Yesterday, the National Disability Insurance Agency (NDIA) announced that the NDIS Pricing Arrangements and Price Limits will be amended radically with effect from 1 February 2025 to change the way music and art therapies are funded.
Many affected providers appear to have been blindsided, with some expressing real fears about the future of their businesses and jobs.
All allied health providers, and NDIS participants, should be worried about the precedent set by the NDIA’s decision-making process, including the way it announced significant changes.

Allied health providers can be paid by the NDIA only for services that are ‘NDIS supports’.
‘NDIS supports’ are now defined in 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.
For allied health providers, key NDIS supports include:
- early intervention supports for early childhood (0-9 years) (Item 17); and
- therapeutic supports (Item 34).

Early intervention supports are defined to include: “therapy provided by allied health professionals including speech pathologists and occupational therapists”.
Therapeutic supports include “supports that provide evidence‑based therapy to help participants improve or maintain their functional capacity in areas such as language and communication, personal care, mobility and movement, interpersonal interactions, functioning (including psychosocial functioning) and community living.” (Our emphasis.)

According to the NDIA:

“While art and music therapy remain permissible, they do not meet the evidentiary standards required to be classified as a ‘therapy’ under the definition of NDIS supports.” (Our emphasis.)
From 1 February 2025, “[p]articipants will be able to access these supports…through their community participation budget:
- At a 1 to 1 rate of $67.56 an hour when delivered by a registered provider.
- At a group rate of $193.99 an hour when delivered to a minimum of 4 participants by a registered provider. This will support participants to have greater opportunities for inclusion and participation in the community.” (Our emphasis.)
“Participants and providers can continue with current arrangements until 1 February when the changes to the price guide come into effect.”
“We understand that the evidence base in relation to art and music therapy is continuing to be developed, as it relates to disability-related support. In recognition of this the NDIA is referring art and music therapy to be assessed by the NDIS Evidence Advisory Committee.” (Our emphasis.)

With its announcement, the NDIA:

has asserted that it can determine a recognised therapy is not supported by enough evidence to be classified as a therapeutic NDIS support;
will reduce the real-world choice and control of NDIS participants because:
- it must know that evidence-based music and art therapies cannot be delivered viably by qualified professionals for $67.56 an hour; and
- even at the lowered rates, appears to require that the services can be provided only by registered providers; and
appears to assume group therapy provides NDIS participants with greater opportunities for inclusion and participation in the community (many NDIS participants and advocates dispute this); and
has set a precedent for referring recognised therapies to an advisory committee – that doesn’t yet exist – to determine the legitimacy of their services for funding as therapies.

Allied health providers and NDIS participants can no longer assume they will be consulted properly about major changes to NDIS funding or service-delivery models.
We should all keep a very close eye on:
- what is happening with the NDIS Evidence Advisory Committee including who will be be on it (expressions of interest close on 17 December 2024) and when it will be set up (potentially not until July 2025); and
- the NDIA’s evolving views on what constitutes evidence-based therapy for the purposes of determining whether a service is an NDIS support.