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

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Consultation on the Government’s proposed lists of permissible NDIS supports ends on Sunday. Many people have strong views about what participants should – and shouldn’t – be allowed to spend their NDIS funding on, including, of course, participants.

Public commentary has been spirited. Pockets of the media have fixated on a few hot topics, like fraud allegations, adult services, and obviously inappropriate spending on things like gambling, alcohol, tarot card-readings, and holidays. 

But state governments, disability advocates, and many providers see a bigger problem brewing. It’s not a new problem, but it’s about to become more prominent and urgent.

Disability vs. Mainstream Services: where is the line? 

As with the current system (and with some exceptions), the proposed “out” list includes “mainstream” government services like health, early childhood development, school education, higher education and training, justice, and aged care. 

In theory, the split seems sensible. People should get the help they need from the most appropriate system. Participants should have the same access to health and education services as everyone else. 

But, in practice, when looking at individual cases, the NDIS/not NDIS distinction is often harder to make than the current rules or proposed lists suggest.

A real world example

To understand some of the complexity, it helps to look at real world specifics, rather than abstract systems. In particular, it helps to focus on the individuals most affected: NDIS participants.  

Take, for example, this Administrative Appeals Tribunal case from 2023. You had an 11 year-old Canberra boy with level 3 autism, a language disorder, ADHD, dyslexia, dyscalculia, and anxiety. The boy was an NDIS participant, probably because of his autism diagnosis. The AAT had to decide whether supports related to his dyslexia and dyscalculia – reading, writing, and maths intervention – should be funded through the NDIS.

Right now, when faced with this type of decision, the NDIA and the AAT have to decide whether specific supports are “most appropriately funded or provided through the NDIS” or through another service system, like health or education. 

In this case, the NDIA argued that dyslexia was a learning disorder, that support with reading was primarily related to educational attainment, and that, therefore, the NDIS was not the most appropriate funder. Instead, the ACT Education Directorate was responsible for helping the boy to overcome his dyslexia. With regret, the AAT agreed.

Sounds logical. So what’s the issue?

The AAT decision seems like a logical application of the rules. Reading, writing and maths are school matters. So what’s the problem? Why was the AAT so reluctant to agree with the NDIA?

Just because a system is the appropriate funder doesn’t mean it actually provides the support 

The evidence in this case established that the school system did not in fact provide a service that could remedy the boy’s reading and writing difficulties. All the school could offer was a bit of in-class help from a Learning Support Assistant who was also supporting other students. The AAT found it was:

“clear from the evidence given at the hearing that this intervention had no prospect of remedying the [boy’s] deficiencies in reading, writing and mathematics” and that the “interventions which the school is making are not sufficiently targeted to make any difference to the [boy’s] ability to read or write or progress in mathematics”.

But the AAT decision saved the taxpayer money, right?

It meant taxpayers didn’t have to pay for dyslexia support through the NDIS. But the longer-term costs to taxpayers can’t be so easily calculated.

The decision left a level 3 autistic, language-disordered, anxious 11 year-old in upper primary school without basic literacy skills. It left him without public funding for evidence-based help to overcome his illiteracy. 

Not being able to read has significant adverse implications for a person’s education. But school ends when you are 17 or 18 years-old. Un-remedied illiteracy lasts a lifetime and, for many people, leads to significant adverse social effects and negative health, work, and justice system outcomes. 

Schools are responsible for making reasonable adjustments to personalise and support students with reading and writing. But, if they don’t actually provide it, illiterate children become illiterate adults. Taxpayers may end up footing a larger bill for longer-term supports from another public service, like health or justice.

No bright-lines

The Canberra boy has a permanent disability. He has health needs. He has educational needs. His disability, health, and education issues interact with each other. His disability, his health needs, and his educational challenges all affect his ability to function and to participate in life. 

In truth, you can’t draw neat lines between disability and mainstream health and education services for people with disabilities, despite what the rules say. As noted by the AAT:

“The rules set up a dichotomy between supports which ameliorate the functional impact of a disability of activities of daily living [which are NDIS-funded] and supports which primarily relate to educational attainment [not funded by the NDIS]….The [boy] in his submissions highlights that there is a relationship between his educational attainment and his activities of daily living and so this strict dichotomy is hard to apply. If a person has not mastered basic…reading, there will be an impact on their functional capacity to undertake activities of daily living.”

The AAT didn’t disagree with the boy’s point, but concluded they did not have discretion to disregard the rules as written.

Remember that taxpayers are on the hook for all public services

Disability and mainstream health and education systems operate independently but are interdependent – and all funded by taxpayers. This was recognised by the Productivity Commission way back in 2011:

“Access to generic services, such as health…can affect demand for NDIS-funded services, and vice versa. It will be important for the [NDIS] not to respond to problems or shortfalls in mainstream services by providing substitute services. To do so would weaken the incentives by government to properly fund mainstream services for people with a disability, shifting the cost to another part of government (such as from a state government to the NDIS…). This ‘pass the parcel’ approach would undermine the sustainability of the [NDIS] and the capacity of people with a disability to access mainstream services.” (My emphasis.)

Arguably, this game of pass the parcel is exactly what’s happened. States have underinvested in funding mainstream education and health services for people with a disability. Too few supports exist for people with disabilities who are not NDIS participants. One of the main reasons so many people fight so hard for access to the NDIS is that it’s the only real help available.

So why’s the problem about to get bigger?

The Federal government has decided to implement ‘foundational supports’ – disability supports outside the NDIS. If you don’t know much about them, check out this excellent summary by Sina Gingold of DSC.

The foundational supports proposal is a good idea in theory. It is intended to ensure the NDIS is sustainable and focused on supporting people with lifelong disabilities, while also supporting people with a disability who are not participants to get support when they need it in childcare, schools, homes, and community care settings.  

Properly funded and skilled front line disability supports in mainstream settings, like schools, could provide exactly the type of help needed by people like the dyslexic Canberra boy. But it has triggered a furious debate between Federal and state governments about the future interdependence of disability and mainstream health and education services for people with a disability and, most immediately, who will fund them. 

It’s no surprise that state governments are asking for more time and a new intergovernmental agreement. They’re facing two main issues: a lack of detail on the funding for these proposed additional mainstream services for people with a disability; and a lack of trained people with the skills and systems to deliver them. 

Conclusion

Most allied health NDIS providers – including speech pathologists, occupational therapists, and physiotherapists – support people to increase their functional skills, independence and participation, consistent with the purpose of the NDIS. 

Ideally, our aims should be to support the whole person in front of us, rather than to focus on arbitrary and false distinctions between an individual’s disability, health and education difficulties. 

In reality, like NDIS participants, we have to operate within different systems and to follow different rules around different supports depending on the system or systems we are working within at the time. Regrettably, this means we sometimes have to work with participants on discrete challenges in isolation, while ignoring significant challenges that may affect the participant adversely more in the longer-term. 

The Canberra boy’s situation is a good case in point. Presumably, he was receiving some NDIS supports for his oral language disorder associated with autism, executive function challenges, and anxiety under the NDIS, while not receiving supports for his written language (reading or writing) despite lots of evidence showing that oral communication skills, mental health, and literacy are related, and that illiteracy leads to poorer longer-term social and mental health outcomes for adolescents and adults.

People with a disability should be able to access support for their health and education challenges like everyone else. Taxpayers fund the NDIS and mainstream services, and games of pass the parcel between governments do nothing to help participants live their lives well. It’s also unclear if they end up saving taxpayers money after you consider the long-term consequences of limiting supports in one system knowing that there are major deficiencies in the system “most appropriate”.  

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

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On Sunday, 4 August 2024, the Federal Government released a consultation paper on draft lists of NDIS supports. It gave everyone only 14 days to respond.

Big Picture

If enacted, the NDIS Amendment (Getting the NDIS Back on Track) Bill will allow the Government to make new rules about what is – and isn’t – an NDIS Support. But Commonwealth and State governments will then need to agree on the detailed rules, which will take time. Until this happens, the Government wants a transitional rule in force, including lists of supports that will – and won’t – be funded.  

Proposed “ins and outs” for allied health-related services

What’s inWhat’s out
Therapeutic supports: “evidence-based therapy supports provided to assist a participant to apply their functional skills to improve participation and independence in daily, practical activities in areas such as language and communication, personal care, mobility and movement, interpersonal interactions and community living”, including “further assessment by health professionals for support planning and review as required”.

Early intervention supports for 0-9 year-olds, including “a mix of therapies”.

Specialist positive behaviour support.

Some disability-related health supports (including some dysphagia, continence, respiratory, nutrition, diabetes, epilepsy, podiatry and wound and pressure care supports).

Communication, information and personal mobility equipment.

Exercise physiology, specialist hearing supports, therapeutic massage directly related to disability, and some interpreting and translation help. 		Alternative and complementary therapies like crystal therapy, tarot cards and clairvoyants, cuddle therapy, reflexology, aromatherapy, sound therapy, yoga therapy, wilderness therapy, alternative or complementary medicine.

Wellness and coaching services like general massage, sports supplements, life-coaching, hypnotherapy, neurofeedback, gaming therapy, mastermind coaching, somatic therapy and kinesiology.

Energy and healing practices such as Reiki, Scalar Lounge, frequency healing and energy balanced massage, deep energy clearing, spinal flow technique and shamanic healing, hair and beauty services (including nail salons).

“Mainstream” services, including health,  mental health, child protection and family support, early childhood development, higher education and vocational education and training, employment, housing and community infrastructure, transport, justice, and aged-care services.  

Lists have limits

Many participants, providers, and taxpayers want clarity on what NDIS funds can be spent on. But the lines between “disability” and “mainstream” services are harder to draw in practice than the lists suggest, and disputes are inevitable.

Will (can) the States cover support gaps for participants and others with disabilities in health and education services?

What happens if governments can’t agree on a future ‘permanent’ rule?

Will we be stuck with the lists?

Have we considered the second– and third- order effects of these changes for participants, state governments, providers, and taxpayers?

It’s very hard to think through these issues properly in the very short consultation period while also delivering services to participants.

Go deeper 

Consultation on draft lists of NDIS supports

NDIS regulatory changes are coming: allied health providers should stick together to advocate for participant choice and control

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For allied health NDIS providers, significant regulatory changes are coming:

Uncertainty abounds. We don’t know what the new rules will look like. We don’t know how they will apply to allied health providers.  

At the same time, we’re grappling with pricing limits, worker shortages, inflation, and other business risks. It’s no surprise that many of us complain about upcoming regulatory changes in terms of mandatory registration, increased compliance costs, and more red tape. 

The danger of all this negative talk about costs and risks is that it sounds defensive and even self-indulgent. But, when it comes to regulation, allied health providers have an overwhelmingly positive story to tell and an important role to play in advocating against changes that could reduce NDIS participant choice and control in the real world. 

Allied health professionals are already well-regulated. Most allied health providers work hard to deliver evidence-based supports to participants, and to improve their service quality in response to participant feedback. Like participants, we want the NDIS to work. We want the NDIS to deliver for participants.

What do we want?

We want participants to have more choice and control over the supports they purchase and the providers they work with. We want the NDIS to be safer for participants. We want the NDIS to be sustainable. We want the NDIS to be cost-effective for participants and taxpayers. We want to stamp out abuse, fraud and other criminal, unethical and bad behaviours. We want more innovation, competition, and investment to increase productivity, service quality, value for money, and options for participants.

What do we not want?

We don’t want to return to the bad old days of pre-NDIS block funding with no participant choice or control. We don’t want market failure caused by a lack of providers. We don’t want anti-competitive behaviours or markets dominated by a few big providers. We don’t want more thin markets or market failures. We don’t want to drive quality providers out of business with increased compliance costs that are disproportionate to the risks or the size of their activities.  

We’re arguing with each other about the wrong things, based on wrong assumptions

In the wider provider sector, too much time and energy is expended arguing about the pros and cons of registered versus unregistered NDIS providers, and their eligibility to deliver different support types to participants. Generalisations infect the debate on both sides. 

Despite the work of the NDIS Provider and Worker Registration Taskforce to allay concerns, some providers assume that mandatory registration will mean the imposition of expensive quality compliance processes and external audits on all providers. Some assume that participants want to work only with registered providers; or that unregistered providers are unregulated cowboys and girls; or that the services of registered providers are guaranteed to be safer and of higher quality than the services of unregistered providers. All these assumptions are false.

Key points we need to communicate better to participants, the Government, and taxpayers 

  • Allied health providers are a diverse bunch. Some of us are big, multidisciplinary, multisite practices, and some of us are part-time sole traders offering mobile services. Some of us are 100% disability-focused, while others provide services to participants and people without disabilities. Some of us work in clinics, while others work in participants’ homes, in schools, workplaces, and a whole range of community and other settings.  
  • Allied health professionals are already well-regulated. For example:
    • Practising physiotherapists, occupational therapists and psychologists are regulated by the Australian Health Practitioner Regulation Agency (AHPRA) in partnership with each profession’s National Board and are subject to AHPRA standards.
    • Certified practising speech pathologists, dietitians, exercise and sports science practitioners, and audiologists are regulated by their professional peak bodies who, themselves, are members of the National Alliance of Self Regulating Health Practitioners (NASRHP), and therefore subject to NASRHP standards closely modelled on AHPRA standards.
    • All these allied health professionals are subject to standards on scope (areas) of practice, codes of ethics/practice and/or professional conduct, complaints procedures, competency standards, course accreditation, continuing professional development, English language requirements, mandatory declarations, professional indemnity insurance, practitioner certification and recency and resumption of practice requirements. 
  • All allied health providers delivering NDIS-funded services are regulated by the NDIS Quality and Safeguards Commission to some degree:
    • Some allied health providers are registered with the NDIS Quality and Safeguards Commission, including some of the larger providers, and providers who provide behavioural supports and/or use (high risk) restrictive practices. Among other things, registration involves providers implementing quality compliance processes to meet NDIS Practice standards and undertaking regular external audits. (In practice, it is time consuming and expensive for providers to get and maintain registration.)
    • Some allied health providers are not registered with the NDIS Quality and Safeguards Commission, including many sole traders, other small providers, and providers who offer their services to both NDIS participants and other clients, and/or service mixes that include disability specific services and other services. These providers are often referred to as “unregistered providers”. However, they are subject to the NDIS Code of Conduct and can be fined and banned by the regulator. 
  • Many participants prefer to work with (generally smaller) unregistered allied health providers or a mix of providers. For example, Professor Helen Dickinson and her colleagues found that many of their interviewed participants spent funds on allied health services and that, “while many allied health providers and therapists are not NDIS registered, these providers typically hold registration or accreditation with their appropriate professional bodies…[and] that NDIS registration would not provide any additional level of safety or quality”.

Best world outcomes

If things go well, we’ll end up with: 

  • a proportionate and graduated regulatory system that takes into account the diversity of allied health provider businesses and services and their existing regulatory frameworks;
  • clear rules that don’t conflict with or duplicate existing rules;
  • a minimum of red tape so we can focus our limited time and resources on service delivery to participants and improving quality;
  • clear communication of the rules to everyone affected;
  • external monitoring of compliance with rules;
  • enforcement when noncompliance is identified; 
  • proper adjudication of disputes about regulator decisions;
  • sanctions for non-compliance; and
  • continuous evaluation and adjustment of the regulatory system as things change. 

Final thoughts

For many allied health providers, the real debate is not about mandatory registration, but about what ‘registration’ will actually mean under the new rules for different allied health providers. To make decisions about the future of our businesses and disability services, we need to know how much it will cost to comply with new rules, how long it will take to obtain registration (whatever that means for a given provider), and how much time (and how many management and worker resources) will be needed to maintain it. An important open question is whether, under the new system, price limit controls will extend to services purchased by self-managed participants. 

The devil will be found in the details. If the government gets this wrong, we’ll see an exodus of allied health providers from the sector, reducing participant choice and control over who they work with for their supports.  

Allied health providers should engage with participants to ensure this doesn’t happen.

Breaking (potentially good) news update

As so often happens, immediately after publishing this article, the NDIS Provider and Worker Registration Taskforce published its Advice. While this will take some time to read through in detail, a quick read of the registration recommendations looks promising for allied health providers:

  • For AHPRA-registered allied health professionals (such as physiotherapists and occupational therapists), the Taskforce has recommended that the registration by AHPRA be recognised as registration for the purposes of NDIS where this can be achieved. (This recommendation is in relation to registration only and does not apply to worker screening.)
  • For self-regulated allied health professions whose peak bodies are members of NASRHP (such as speech pathologists and dietitians), the Taskforce has recommended “consideration be given to the appropriateness of extending a recognition of those registration schemes to self-regulating allied health professionals, noting that any such assessment would need to consider the requirements of the self-regulated environment and other relevant matters”. Again, this recommendation is in relation to registration only and does not apply to worker screening.

If this advice is accepted, it has the potential to considerably reduce the regulatory burden associated with reporting to two regulators (e.g. the NDIS Commission and AHPRA/peak bodies) and to streamline the process for practitioners. As the Taskforce notes, “it would remove the main barrier to registration which has been raised with the Taskforce by allied health practitioners who are currently not registered NDIS providers”.

But, of course, a lot will depend on specifics, and the Government’s response to the recommendations.

Blood from a stone: What allied health NDIS providers can do to improve their lot

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Allied health providers in the NDIS space are struggling. Some are reducing or ceasing work with NDIS participants; and others are shutting down. Stress across the sector is palpable.

Costs increase, but NDIS price limits remain frozen. Governments tell us to do more with less, but the head of our Productivity Commission appears to think that it will always be difficult to increase our productivity because we are labour intensive, and that we’re a drag on Australia’s overall economic growth. In the press, and on social media, ethical providers continue to be lumped together with providers alleged to have ripped off participants and/or underpaid workers. 

It’s grim. 

I’m a realist. Like Joseph Tussman, I think that everything in life is easier to navigate if you identify how the world really works and then align with those realities. Fair or not, the pricing decision is a reality. Inflation is a reality. Anti-provider sentiment from influential voices in government and the media is a reality. Ongoing uncertainties about NDIS sustainability, regulation, and reforms are realities, and will remain that way for some time yet.   

So what can we do to keep going? 

There is no magic bullet. But, to get some perspective and ideas from outside the industry, I’ve been reading research and white papers. This week, Working Future: The Australian Government’s White Paper on Jobs and Opportunities, caught my eye. 

I learned some useful things:

  • Economy-wide productivity growth is slowing: Since the mid-2000s, productivity growth has slowed in Australia. Australian businesses – especially in the services sector – have been slower to adopt new technologies and processes than businesses overseas. This is a big challenge if we want to maintain wages and living standards. 
  • Our sector is growing: Our sector – the care and support economy – is expected to grow by 22% by 2033. The sector includes the work of child carers, child care centre managers, early childhood educators, education aides, welfare support workers, personal care workers, nursing support, diversional therapists, enrolled and mothercraft nurses, Indigenous health workers, social professionals, registered nurses, nutritional professionals, occupational therapists, physiotherapists, podiatrists, audiologists, speech pathologists, nurse managers, and health and welfare service managers.
  • We employ a lot of people: The healthcare and social assistance economy is the fastest growing part of the labour market. We represent about 10% of Australia’s workforce, and this growth is expected to continue.  
  • Our sector needs to improve its employment practices: Across the care sector, staff turnover is too high, probably due to a range of factors including uneven service quality, pay (including gendered undervaluation of work in female-dominated industries where women make up 76.5% of the workforce), work conditions in some settings, relatively high rates of casual employees (28%), too many workers working multiple jobs, and unclear career progression opportunities. 
  • Our sector needs to improve its training practices: Healthcare and social assistance have the highest prevalence of workplace training in the economy, probably because ongoing training is required as part of occupational accreditation. However, time and financial constraints are barriers to quality training for both providers and workers. Some providers are ambivalent about investing in staff skills and training because of high worker turnover. (This is short-sighted, to say the least.)
  • Our workers have other options: Within the sector, different providers demand similar skills and compete for the same workers. But different sub-sectors (e.g, childcare, health, the NDIS, aged care, veterans’ care) are accessed, funded and regulated differently. If one sub-sector becomes dysfunctional or uneconomic, many of our workers have other options – in and outside the sector. So, too, do many providers.

Clear-eyed choices 

If we accept these realities – and we must – providers have three main options:

  1. Shut down NDIS activities altogether and do something more (economically) productive – whether in the sector or elsewhere. (This would not be a good outcome for NDIS participants, especially in rural and remote areas.) 
  2. Reduce NDIS work and work more with other client groups not subject to price controls to offset the losses made on NDIS-funded work.
  3. Stay focused on NDIS-funded work and become more productive to re-establish margins and stay in business. 

If we choose options 2 or 3, we need to raise our productivity. But, given all the constraints, how?

Ideas

In the White Paper, the Government makes a number of suggestions for employers to ‘reignite’ productivity, including that we:

  • increase our management capabilities (currently relatively limited on average, compared to US firms, for example);
  • adopt “innovative work practices…better models of care and support and best practice processes and techniques”;
  • invest more in people and technology to change our models of care and to increase our clients’ choice and control and access to support, including in regional areas with thin markets (e.g. through telehealth);
  • improve our mixes of staff, qualifications and skills;
  • make more efficient use of existing resources by allowing staff to deliver multidisciplinary care;
  • train workers to use robots, automation tech and/or AI to allow workers to focus on higher value activities (e.g., problem-solving, interpersonal and non-routine tasks), and to access and process information, complete mod-level professional writing tasks, make decisions, and undertake admin tasks more efficiently; and
  • accept that ‘firm exits’ (i.e. businesses shutting down) are something that is necessary and perhaps (from the Government’s perspective) desirable to free up workers and capital to move to more productive businesses. 

Many of these suggestions lack specificity. Almost all require investment and additional risk-taking, which is hard to stomach in the current economic environment.

It’s clear from the White Paper that the Federal Government knows that it’s always been difficult to achieve productivity gains in our sector. If we want to improve provider productivity across the system, we need the Government to step up, too, to revisit policy settings on training, occupational licensing, skilled migration, and ‘knowledge translation’ collaborations between businesses, universities and government institutions. We need regulatory certainty (something sorely lacking at present) and harmonisation across sectors and States to resolve inconsistent rules, reduce red tape and admin busy work, and remove barriers to worker mobility (e.g. by consolidating worker screening regimes). 

The NDIS and the care and support sector as a whole are complex adaptive systems. They are made up of individuals who have freedom to act in ways that are not always totally predictable. The actions of governments, regulators, providers, workers and NDIS participants are interconnected: one group’s actions can change the system for everyone else, potentially in unexpected ways.

Bottom line

Ethical providers need to do something if we want to continue to provide high level care to NDIS participants while investing in our workers and staying in business. 

We need all the good ideas we can get.

Further reading:

Working Future: The Australian Government’s White Paper on Jobs and Opportunities | Treasury.gov.au

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?

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

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If you are a private allied health business owner who works with NDIS participants – you should take a look at the Deloitte Access Economics report about NDIS price limits for therapy supports and the Ability Roundtable 2023-24 Annual Price Review Submission about Therapy Supports.  

Both are harrowing reads for occupational therapists, speech pathologists, physiotherapists, social workers, and other allied health businesses. They suggest that most of the bigger, NDIS-registered allied health therapy businesses operate at – or below – break-even point against NDIS price limits. For the 2024-25 financial year, the Ability Roundtable has projected a median loss (net margin) of -14.2% for larger registered providers of therapy supports.  

For registered and unregistered NDIS providers, the real costs of providing therapy supports to participants are often underestimated, including by many allied health business owners. Costs include:

  1. staff base wages and salary oncosts (e.g. annual leave, personal leave, public holiday leave, long service leave, and parental leave, superannuation, workers compensation insurance); 
  2. costs of supervision, training, professional development, and accreditation;
  3. non-billable (but necessary) activity costs, like non-billable client, travel and cancellation time;
  4. service delivery overheads, including occupancy costs (e.g. rent and electricity), motor vehicle fleet costs, specialised equipment, IT costs (e.g. laptops and software), and client consumables;
  5. non-service level staff costs (e.g. team leader and corporate governance costs);
  6. corporate overheads, e.g., IT, finance, human resources and recruitment, insurance, administration, marketing, quality control, and audit and legal expenses; and
  7. NDIS and other compliance costs. 

From Deloitte’s report, it appears that many of the bigger registered allied health businesses have a major structural business problem: high (and rising) fixed costs, a limited capacity to reduce variable costs without affecting service quality or access, a limited ability to increase staff productivity without increased turnover, and of course no room to move on prices. 

The Government’s decision to freeze NDIS therapy prices for another year increases financial pressures on allied health providers. To stay in business, allied health providers must (at least) break even. But we face several difficult choices and tradeoffs as we try to get there:

  1. We can’t lower wages without losing staff to higher paying opportunities, e.g. in the public sector.
  2. We can’t reduce new graduate and early career hiring and support without affecting the future of our professions (onboarding new graduates and building their caseloads requires significant investment and time, which affects average utilisation rates).
  3. We can’t ask frontline staff to see more clients without increasing staff burnout and turnover.
  4. We can’t cut corners on supervision, education and training without reducing the skills of our workforce and the quality of our therapy services.
  5. We can’t recalibrate staffing levels to match fluctuating client demand patterns (e.g. during school holiday periods) without reducing full-time employees and switching to casuals and contractors and reducing continuity of service to some participants.
  6. We can’t reduce investments in corporate governance controls without increasing business and client risks, including to safety.
  7. We can’t narrow our scope of services (e.g., switching to lower-cost supports or private client work outside the NDIS) without reducing NDIS participant access to our services.

For ethical reasons, many of these options and trade-offs are unacceptable for reputable allied health providers.

In the bleak business environment depicted in the Deloitte and the Ability Roundtable reports, it would be logical for:

  1. more registered NDIS allied health providers to deregister, continuing the trend described in the NDIA’s latest Annual Pricing Review;
  2. some allied health providers to downsize and to cut investments to reduce costs; 
  3. some allied health providers to cease working with participants with complex (higher cost) needs and to reduce (higher cost) in-community services to reduce losses; and 
  4. some allied health providers to pivot their businesses to focus on non-NDIS clients to reduce their exposure to NDIS price controls.

Unless allied health NDIS providers find new ways to increase productivity and to re-establish sustainable margins, we may end up with fewer registered allied health providers, fewer larger allied health employers, uneven levels of supervision, training and support for staff across the professions, and fewer options for some NDIS participants to access quality therapy supports. 

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