How many times did the NDIA update the NDIS Price Guide and Support Catalogue in 2019?
- 2 times
- 4 times
- 6 times
- We’ve lost count
The NDIA introduced a long list of changes last year. There are new line items, substantial price increases and new rules regarding billable hours. Listing all changes would be impossible however if you answered A, B or C to the question above you could have overlooked some. As a result, your organisation may miss out on critical funding or potentially charge incorrectly. As a provider, you need to make sure you know and understand the Price Guide. Your organisation needs to comply with Australian consumer law and the Competition & Consumer Act, as well as treat your customers fairly and charge in accordance with the rules.
An updated list of the legal requirements of NDIS providers is available on the NDIS website here. This includes declaring your prices to participants before delivering your service and providing receipts to participants.
Here are some important NDIS Price Guide and Support Catalogue rules:
Cost of administration
The administrative burden for providers continues to be heavy. The Price Guide explicitly outlines that providers are not able to charge for administrative costs, which includes staff rostering, staff training, quoting and payment claims. Pre-engagement meetings with clients to develop and agree on service agreements are also considered non-billable tasks.
There are however exceptions where administrative tasks can be charged against a participant’s plan.
NDIA reporting
Capacity building supports generally require progress reporting to the participant, the NDIA and sometimes a support coordinator, to outline objectives, goals, progress and recommendations. Time spent on the documentation can be charged using the same line item as the primary support, but must be identified as NDIA reporting (or ‘Non Face to Face Service’ for health supports under core supports). If in doubt, the Support Catalogue identifies all supports where report writing is billable – if outlined in your service agreement with your clients.
Writing a report
This is a billable non face to face activity if the report is part of delivering a specific support to assist the participant to achieve their goals. The Price Guide states the example of writing a report for co-workers and other providers about the client’s progress with skill development. Unfortunately, the NDIS does not list any other examples, however we would consider reports for risk assessments as well as incident reporting to fall into this category. Quoting the time in advance for non face to face charges becomes challenging. Service agreements need to pre-authorise chargeable non face to face services and cannot be charged as an ongoing, standardised fee. Non face to face time needs to be identified in the claim (Non Face to Face Service or NF2F).
Support documentation of community access supports
If you are providing assistance with social and community participation, you are able to charge for the time you spend on documenting the proposed supports and expected outcomes. You can claim up to four hours of support, but only if arranged with the participant in advance. Quality programs require groundwork, however you cannot charge for the time you spend preparing for the support or any other non face to face activity.
Billing for cancellation
Many service agreements still contain the ‘3pm the day before’ notification rule for cancellations. This rule was modified in July 2019. There is no obligation to tighten your cancellation policy, however if you prefer to change to the minimum requirement of ‘two clear business days of notice’ (for a service under $1000 or for eight hours and less) the service agreements need to be amended and your clients need to agree to the amendment. Providers can recover 90% of the service fee. If you are claiming on the portal you need to claim for 100% and identify that the service was cancelled (Cancellation Charges or CANC) and the NDIA will pay 90%. You also need to list the reason for the cancellation (health reasons, family issues, lack of transport, other). You will not be able to charge your client if you fill the service time with a different client or if you do not have to pay your worker.
In the early NDIS days, providers had to keep an accurate record on the number of cancellations. This no longer applies, however keeping track of your clients’ cancellations is best practice. As a provider, you have a duty of care. If cancellations are frequent, you will want to know what’s causing the cancellations and assist where possible.
Provider travel
For most off-site services, providers can charge for the time it takes to travel from the office to the client, to compensate for the worker’s time while travelling. Sole traders can charge for the travel time from home to the client if this is a registered business address. The charge is capped to a maximum of 30 minutes in metropolitan areas and 60 minutes in regional areas. Providers of core support cannot claim for the time returning to the office, while providers of capacity building supports can charge for the way back – up to the maximum time limit in their area. The Support Catalogue lists all supports that allow providers to charge for travel time, if specified in the service agreement. To claim for travel time, providers use the same line item as the support claim, and identify ‘Provider travel’ at the same hourly rate or lower, as agreed with the participant. Predicting travel times and quoting for the provider travel costs ahead of the service remains challenging. The cost of the vehicle and petrol is a business expense and cannot be charged against the participant’s plan.
Participant transport
This is where the provider and the participant travel together e.g. the support worker drives the participant to assist with shopping. This is usually part of a community access support. The worker’s travelling time is part of the service provision time and does not need to be claimed separately. The cost of the transport itself (cost of the vehicle and petrol) is the responsibly of the participant and the provider can invoice the participant directly. The cost can only be claimed from the NDIS plan if transport funding is included in the participant’s core budget. The line item has no set price and the rate needs to be negotiated with the participant in advance, and set out in the service agreement. Some providers charge a fixed fee for local trips or underwrite the cost of transport due to the administrative burden of keeping accurate records and invoicing.
This week the NDIA announced that as from 1 March 2020 providers will be able to claim some of their vehicle running costs from participant’s plans. If discussed and agreed providers can claim up to $0.85/km for standard vehicles and $2.40/km for modified vehicles or buses.
Disability-related health supports
The NDIS has been funding disability-related health supports since October 2019, where the supports are a regular part of the participants’ daily life and the need for support results from the participant’s disability. There are eight support type categories. Newly introduced line items under core supports should help participants to purchase health supports with unspent core budgets until they have a plan review. The therapeutic supports available through core funding are restricted to health supports only (which was updated in the December 2019 Price Guide update). Other therapeutic supports should be claimed under the capacity building line items.
The NDIA has announced the publication of an updated NDIS Price Guide and Support Catalogue in the coming weeks which will be valid from 1 March 2020. The Annual Price Review has also started and the NDIA will publish a draft report of findings in February or March with an opportunity for feedback. This will give an insight into what changes we might expect in the July 2020/21 Price Guide. Until then, make sure you know the current Price Guide and your obligations as a provider!
