Funding and delivery of services
This chapter examines the funding and delivery of ECEI services, and
reviews issues raised by families, carers and service providers. The chapter considers
Participant views on the costs of assessment and diagnosis, the adequacy for
support needs and reported delays in service delivery. The chapter also
considers service providers' views on service costs; regulated pricing, gaps in
funding and workforce issues.
Assessment and diagnosis reports
reported that families have to partially, and sometimes fully, fund assessment
and diagnosis reports to provide evidence of their child's need for support and
access the funding they need. The costs of these reports can be significant and
are, at best, only partially subsidised. As highlighted in the evidence below,
the issue of sourcing assessment reports is particularly relevant to families
with children on the autism spectrum.
In its submission, the Victorian Autism Specific Early Learning and Care
Centre noted that 'families often report feeling pressured to source a private
assessment team, at great cost, to get a diagnosis and access the funding they
In 2017, AMAZE, the peak body in Victoria for people with autism and
their supporters, conducted a survey of parents and carers of NDIS ECEI Participants.
The survey found 36 per cent of respondents incurred costs to access the NDIS
ECEI pathway (that is, costs for initial diagnosis and providing evidence of
reasonable and necessary supports).
At a public hearing in Melbourne, Mr Braedan Hogan, Manager, Public
Affairs and NDIS Transition at AMAZE, reported that some people with an
existing diagnosis are asked to obtain an up-to-date diagnosis at a personal
Public health system
The committee heard that, due to long waiting lists in the public health
system and limited Medicare rebates and services, families are self-funding
assessment and diagnosis reports. For example, the grandmother of a boy with
autism stated she 'borrowed money to pay for an assessment of [name of grandson
withheld] as the public wait time was around 1 year'.
Similarly a family 'self-funded occupational therapist, psychologist and speech
pathologist assessments as the NSW Health waiting list was too long—12 months
The Australian Psychological Society Limited also reported that 'waiting lists
for assessment in the public sector are lengthy (commonly 1–2 years, but often
longer) and are not available in many parts of Australia'.
There are only limited rebates under Medicare for these assessments. The
Australian Psychological Society Limited explained:
Only some children will meet criteria for an assessment to be
done under Medicare, and even then there is likely to be a substantial gap fee.
[...] some children may be eligible for a Medicare rebate for
an assessment for ASD. However, the rebate only supports a limited assessment
and is significantly below the fees recommended by the APS. This means that
many families pay full fees or a significant gap fee if the child is eligible
for a Medicare rebate.
Some diagnosis testings are not covered at all by Medicare. For example,
the cost of genetic testing for SWAN Children (children with Syndromes Without
A Name) is expensive and not covered by Medicare. SWAN Australia reported that
the approximate cost for a singleton Whole Exome Sequencing (WES) is $2500, and
$5000 for a trio WES Syndromes.
RDI Consultants Australia, an association representing and supporting
RDI Certified Consultants and Trainees who provide the RDI (Relationship
Development Intervention) Program, reported that assessments can cost $450 to
One of AMAZE's survey respondents reported spending a total of $1200 on
The costs of private diagnosis for Autism Spectrum Disorder (ASD) are
high. According to the Australian Psychological Society, it is at least $2000
and is not covered by private insurance.
Dr Jessica Paynter, a Member of the Australian Psychological Society described
the situation and consequences for families:
We're also seeing then that there is a gap where there is no
funding for things like an intellectual assessment to demonstrate cognitive
impairment. And a private assessment for a cognitive assessment or for an ASD
assessment can be upwards of $2,000 to $3,000 per child. That's a substantial
cost that is either borne by families—or they're coming in to Planners without
evidence of their child's level of need, which makes it challenging to advocate
for the supports that they require.
Occupational Therapy Australia argued that it is placing families who
cannot afford assessments at a significant disadvantage.
Annual assessment when on a plan
Current NDIS Plans cover the cost of an annual assessment. However, best
practice in early intervention for children with hearing loss is to undertake
biannual assessments, to allow clinicians to review a child's progress and
adjust services as appropriate in order for a child to achieve optimal results.
Hear and Say recommended that the assessment protocol be updated to allow Plans
to include funded biannual assessments for children with hearing loss.
The committee is concerned that some families have had to fully or
partially fund assessment and diagnosis reports to ensure their child could
access ECEI services and have adequately funded Plans. The committee is also greatly
concerned that some families feel pressured to pay for costly assessments to access
funding and services.
As discussed in chapter 2, there should be no need for families to
provide these costly assessment and diagnosis reports at the time of lodging
the access request for ECEI services with the NDIA or during the Planning
process. Furthermore, if the NDIS has made a request that a prospective Participant
undergo an assessment or examination, the NDIS operational guidelines and the
NDIS Act stipulate 'the NDIA will support the prospective Participant to comply
with the request by providing assistance, including financial assistance where
The NDIA needs to clearly communicate to families, Planners and ECEI Partners
that assessment reports are not needed unless requested by the NDIA. The NDIA
should pay for the costs of assessment and diagnosis it requests from
prospective and existing Participants.
The committee believes that adequate provision of funding for
assessments should be made available in Plans if considered necessary by
clinicians, and not be limited to funding for an annual assessment if better
results can be achieved with more frequent assessments.
The committee recommends the NDIA clearly communicate to families, Planners
and ECEI Partners that assessment reports are not needed unless requested by
The committee recommends the NDIA ensures provision of funding for
assessments in Plans is based on the Participant's needs and is not arbitrarily
restricted to a yearly assessment.
Funding in plans
Some inquiry participants reported significant funding shortfalls in Plans
under the ECEI Approach.
In response to AMAZE's ECEI survey, only 54 per cent of respondents felt
satisfied that the amount of funding provided was adequate to meet their child's
early intervention support needs.
One of the survey respondents estimated 'that the funding is 40 per cent to 50
per cent below requirements'.
Children and Young People with Disability Australia (CYDA), provided
examples of some family experiences that highlight issues of significant
funding shortfalls in Plans:
Lack of funding has limited the access to supports in general
and excluded some others. Our child's plan was cut from $32000 to $16000 in the
second year and this has had a major impact.
We have just applied for the NDIS and received a first
package which is half of what we applied for. We are currently launching an
The committee also heard from the grandmother of a three year old boy
that his Plan is currently underfunded by $50 000.
Underfunded plans for children with
Submitters expressed concerns about the inadequate level of funding ECEI
Participants with autism are commonly receiving.
The Australian Psychological Society indicated that NDIS funding levels
are lower than previous national funding models such as Helping Children with
The Australian Psychological Society pointed out that current funding
levels make it difficult to achieve good outcomes:
Current funding levels are not commensurate with recommended
best/good practice guidelines in Autism Spectrum Disorder (ASD) of 15-25 hours
per week making it difficult for consumers to obtain good outcomes.
Similarly, Victorian Autism Specific Early Learning and Care Centre submitted:
The funding ECEI Participants with autism have received does
not align with evidence-based practice. The NDIS publication, Autism spectrum
disorder: Evidence-based/evidence-informed good practice for supports provided
to preschool children, their families and carers (Roberts and Williams, 2016),
recommends 15-25 hours per week of evidence based, early intervention for
children with autism. However, thus far, NDIS Plans have only supported such
intensity for children who are severely impaired. Children with mild-moderate
autism have received limited funding and do not enable them to access the
recommended intensity of intervention.
At a public hearing in Sydney, Mrs Tina Skapetis, a mother of a girl
diagnosed with autism, reported:
In late November 2016 the NDIS advised that Emanuella's plan
had been approved for $22,000 for 12 months. This was $38,000 short of what we
needed. We were devastated. There was no way that we could afford to fund the
shortfall. I expressed my disappointment, only to be told by the planner that I
should be grateful for what I have gotten, as other families got only $17,000.
In its submission, the Victorian Autism Specific Early Learning and Care
Centre relayed stories from parents of children with autism who received
inadequate funding in their child's Plan:
Parent 2: [...] Funding was not enough to cover everything we
needed. [...]We had to cut therapies to make the funding we had last. We are
still going to run out before review, and are having to obtain loans to bridge
Parent 4: [...] Her plan was approved in May, for 39 hours, or
$6900, which is woefully inadequate for what she needs.[...] Next year, I will
have to pay for private therapy (OT, speech and psych) to supplement funded
therapy if we have the same amount.
Underfunded Plans for deaf and hard
of hearing children
The committee recently reported on the issue of underfunded Plans for
deaf and hard of hearing children in its interim report Provision of Hearing
Services under the National Disability Insurance Scheme,
released in September 2017.
During the course of the inquiry, submitters from the hearing sector
continued to report that Plans for deaf and hard of hearing children are
generally underfunded and not meeting children's reasonable and necessary
First Voice and its members reported that families customarily receive
NDIS funded Plans that are $6000–$10 000 per child per year less than the actual
costs of services.
Mr Michael Forwood, Chair of First Voice noted:
So, most children who are entering into the specialist
language development programs are now getting $6,000, against a cost of between
$18,000 and $22,000 for a comprehensive multidisciplinary program.
Mr Bart Cavaletto from the Royal Institute for Deaf and Blind Children
told the committee that 'the plans that families are getting in no way reflect
the cost of delivering services'.
Inconsistencies in funding
As with other cohorts in the Scheme, variations in types and amounts of
funded support in NDIS Plans for children with similar needs remain a
The Commonwealth Ombudsman reported that 'ECEI providers expressed
frustration and concern that children in very similar situations could receive
NDIS Plans with vastly different types and amounts of support'.
The Royal Institute for Deaf and Blind Children found that 'the scope of
supports provided to Participants in their Plans is highly variable despite similarities
Early Childhood Intervention Australia Victoria/Tasmania and others
suggested that variations in funding can be attributed to parents' ability to
advocate for their child's needs:
Inequities have been identified by service providers in many plans
indicating parents who are better able to advocate for their child's needs or
those who are supported through the process are receiving better supports and
Variations and inconsistencies in funding have also been attributed to
the lack of knowledge and expertise of NDIS Planners.
The issue of funding for assistive technology in Plans was raised by
Submitters noted inconsistencies in funding, approval and rejection of
assistive technology, which can lead to suboptimal or inappropriate equipment
being given to children.
Ms Gail Mulcair, CEO of Speech Pathology Australia, reported that some Participants
are given inappropriate assisted technology equipment in their Plans to reduce
We certainly see these decisions occurring around trying to
limit the cost, in the situation of an AAC device or a communication aid, as an
example, or other assisted technology equipment, that there is a cap on the
expense. Decisions are being made around defaulting to something which may be
more affordable but may not be appropriate, or certainly that has been
recommended as not being appropriate for that child or in the case of adults.
Participants expressed concerns about funding for non-specialised
technology, such as tablets being rejected in Plans despite being relatively
low cost, to meet the needs of some NDIS Participants.
Deaf Services Queensland explained how tablets can reduce expenses to
the NDIA over the short and long term by 'enabling children to participate in
therapy or Teacher of the Deaf services via tele-practice, thereby increasing
efficiencies and decreasing the impact of travel distances'.
Ms Michelle Crozier, NDIS Project Manager, Deaf Services Queensland,
We want to be able to deliver our services remotely through
videoconferencing, and people need tablets for that—particularly for
interpreting. We have arrangements with hospitals like Townsville Hospital,
where they have an iPad and we do remote interpreting. But we can't do that
under the NDIS for individual participants because a tablet or device that will
support that can't be funded.
Mrs Rachel Tosh, General Manager at Therapy Alliance Group, reported the
Just this week, we had a child where the therapist had
recommended an iPad with a specific app for communication. The child's already
familiar with the app from school, so it would provide a cost-effective
alternative and augmentative communication method for this child. We were
informed not to put in an AT request for the iPad, because it wouldn't be
funded, because it's not a disability specific support.
Deaf Services Queensland noted that tablets were previously funded under
Commonwealth schemes such as a Better Start and Helping Children with Autism
Similarly, Myhorizon noted that therapy resources such as Sensory Aids
(weighted blankets, vests, and mini-trampolines) and Assistive Technology
(iPads) are not being approved, but that 'these therapy resources are funded
via Better Start and HCWA'.
A respondent to AMAZE's ECEI survey also reported that 'the NDIA refuses
to fund sensory equipment that would make a big difference to my child's
Many submitters raised concern about the lack of funding in Plans for
interpreters and translators.
Noah's Ark Inc explained:
The NDIS has a rule that it will not support the cost of
translators. This means that non-English-speaking families cannot understand,
gain information from services about their child's condition or the supports
they need to provide. This rule undermines the purpose of early intervention.
Occupational Therapy Australia reported that 'concerns have also been
raised about the decision to no longer fund interpreters, and how this will
affect service providers who are unable to afford the fees for an interpreter
to communicate with parents from culturally and linguistically diverse (CALD)
The Victorian Government is also concerned about the lack of funding for
interpreter services and how this may affect the quality of services provided
They submitted that the NDIS 'should fund interpreter services for culturally
appropriate service provision'.
Similarly, Autism Spectrum Australia recommended 'funding for
interpreters and translators as part of NDIS packages (not just for the Planning
process) as this cost is not able to be met from NDIS funding'.
Support for families, carers and
The lack of funding and support available for families, carers and
siblings was raised by several inquiry participants.
Syndromes Without A Name (SWAN) Australia is of the view that 'funding
needs to be directed into supporting families when they are first told there is
an issue with their child's development'.
It recommended funding for counselling be made available for families and
carers who care for a child newly diagnosed.
KU Children's services pointed out that because the NDIS focuses on
individual supports, group support programs which supported families are no
longer adequately funded to operate.
Submitters argued that the needs of siblings are being overlooked in the
ECEI Approach and highlighted that siblings of children with a disability or
developmental delay can experience a range of challenges, such as ongoing
stress, which can affect their health, well-being, and contribution to society.
At a public hearing in Adelaide, Ms Kate Strohm, Founder and Director of
Siblings Australia, explained the important role of siblings:
Siblings are also a key component of the sustainability of
the NDIS. They are a major part of the informal support for a person with
disability. But, again, there is no support for them. They are a key part
succession planning as parents become older. Often, siblings will step in and
take over that role.
Ms Strohm also pointed out the lack of dedicated policy or funding for
sibling support under the NDIS:
Siblings are not in policy anywhere. There is a lot of
rhetoric about families, but, unfortunately, here there is no mention of
siblings. This is unlike in the UK, where the Children Act states that the
needs of brothers and sisters should not be overlooked—they should be provided
for as part of a package of services for the child with a disability.
One submission provided a number of practical examples of how siblings
could be supported, including through therapist facilitated sibling support
groups or through individual therapy and counselling.
In response to the committee's question on supports available for siblings,
the NDIA stated:
The National Disability Insurance Scheme funds supports that
families need as a result of a family member's disability, such as:
- family support and counselling due to a family member's
- building the skills and capacity of other family members to
manage the impact of a Participant's disability on family life;
- supports that increase the Participant's independence, as
well as supports that enable the Participant to enjoy social and community
activities independent of their informal carers; and
- supports aimed at increasing the sustainability of family
caring arrangement, including personal care and domestic assistance related to
the person's disability.
The committee is concerned with the numerous reports of significantly
underfunded Plans for ECEI Participants. The committee notes that the funding
shortfalls and inconsistencies in Plans appear to particularly affect children
with autism and those with hearing impairments.
Underfunded plans for children with
The committee received concerning evidence in relation to recurring
funding shortfalls in Plans for children with autism. It appears that the level
of funding granted in many Plans does not meet Participants' needs and does not
align with recommended evidence-based practice guidelines. This is resulting in
those children not accessing the right level of support and therapies to
achieve optimal outcomes.
Alarmingly, the committee heard that NDIS funding levels are often lower
than previous national funding models such as Helping Children with Autism. It
is concerning that some Participants and their families are potentially worse
off than under previous funding models.
With almost 40 per cent of NDIS Participants age 0–6 years having autism
as their primary disability, it is of paramount importance that the NDIA
urgently addresses the issues of scope and level of funding in Plans for
children with autism.
The committee recommends the NDIA urgently address the issues of scope
and level of funding in Plans for children with autism with a view to ensuring
that recommended evidence-based supports and therapies are fully funded.
Underfunded plans for deaf and hard
of hearing children
The committee has already made a number of recommendations in its
interim report Provision of Hearing services Under the National Disability
to address funding shortfalls in Plans for deaf and hard of hearing children.
The committee reiterates its concerns regarding funding levels in Plans for
deaf and hard of hearing children. The committee urges the NDIA to implement the
Provision of Hearing Services Under the National Disability Insurance Scheme
recommendation 5 in relation to early intervention packages.
The committee recommends the NDIA implement the Provision of Hearing
Services under the National Disability Insurance Scheme recommendation 5 in
relation to early intervention packages which says:
The committee recommends NDIA ensures that the early
intervention packages take a holistic approach to the needs of Participants and
scaled funding, depending on need;
funding provision for additional services beyond core
supports, depending on need; and
retrospective payment of the costs borne by approved service
providers for the provision of necessary and reasonable supports between time
of diagnosis and Plan enactment.
The committee believes that approval of funding for assistive technology
should be systematically and consistently based on the Participant's individual
needs to achieve optimal outcomes. The funding decision should not be based on
minimising costs. As a result, the committee is concerned that some submitters suggested
that Participants were given inappropriate assisted technology equipment to
reduce costs. The committee acknowledges the existing NDIS operational
guidelines on funding assistive technology available on the NDIS website.
The committee recommends the NDIA further clarifies in its guidelines its
definition and interpretation of minimum necessary and standard level
to determine funding for equipment in a Participant's Plan.
A major source of concern for families is the rejection of funding requests
for certain items such as iPads, despite being recommended by therapists. According
to the NDIS operational guidelines, the committee believes there is no reason
for rejecting a request for a tablet or sensory equipment if it meets the
[...]allows a Participant to perform tasks that they would
otherwise be unable to do, or which increases the ease and safety with which
tasks can be performed. [...] In addition to enabling Participants to be more
independent or participate more fully in daily activities, assistive technology
reduce the need for assistance;
make assistance safe and sustainable; or
prevent or slow the development of further impairment.
The committee believes the NDIA should clarify its guidelines in
relation to funding non-specialised equipment.
The committee recommends the NDIA reviews and clarifies its Operational
Guidelines on funding for assistive technology with the view of ensuring that Participants
can access the most appropriate equipment to meet their needs.
The committee is concerned that costs for interpreters for families who
need them appear not to be appropriately covered in Plans. The committee notes
there is no specific information in the NDIS Operational Guidelines about
supports in Plans for interpreters. However, there is a factsheet about
Translation and Interpreting Services (TIS) available for Participants or their
parents or carers which states that Participants with a Plan from a CALD
background can access assistance from the National Translation and Interpreter
Services when engaging with NDIA registered service providers.
The committee believes the NDIA needs to clarify its Operational Guidelines
and ensures provision of funding for interpreters to enable efficient
communication with Participants and their families.
The committee recommends funding be made available in Plans for
interpreters, including funding an interpreter to communicate with the Participant's
parents or carers.
Supports for families and carers
The committee believes access to supports for families and carers should
be integral to the ECEI Approach. The committee agrees that, to date, the role
of siblings of children with disability has been overlooked within the
framework of the NDIS and its ECEI Approach. The committee believes that the
NDIA should consider the development of sibling specific supports and how these
could be integrated into the ECEI Approach. Development of tailored programs
should be considered and delivered through the Information, Linkages and
Capacity Building (ILC).
The committee recommends the NDIA consider allocating specific funding
for the development and provision of tailored support programs for parents,
carers and siblings of children with disability through the ILC.
Delays in accessing and receiving services
As described by CYDA, 'early childhood is a well-established pivotal
time for development and it is critical that children and families have timely
access to expertise, services and supports during this time'.
Many submitters are thus concerned about the delays in receiving
services under the ECEI Approach and the negative impacts these delays can have
on the success of therapies and the future of their children and families.
Delays are not just occurring during the process to determine access to
ECEI services and Planning phase to devise a first Plan but also once a child
has a Plan.
Ms Fleur Beaupert, Policy Officer at CYDA, reported that families
experienced 'lengthy delays in accessing services' with some families 'waiting
up to 18 months before accessing services'.
Similarly, Ms Teigan Leonard, Team Manager/Psychologist at Kalparrin
Early Childhood Intervention Program Inc commented that they had 'families who
have had to wait in excess of 90 days to be able to access any of their funds'.
The Royal Australasian College of Physicians expressed concern over long
delays in South Australia for vulnerable children. This includes 'children in
South Australia under the Guardianship of the Minister (GOM) waiting around 12
months between enrolment in the NDIS and therapy commencing'.
First Voice gave the following example from a service provider in South
Cora Barclay Centre statistics show there have been 48 new
ECI referrals since the NDIS started of whom 11 (23%) commenced services with
us 12 months or longer after confirmation of diagnosis. These include 3 who
have taken longer than 2 years.
reported similar concerns, including Deaf Services Queensland, which attributes
some of the delays in provision of services to provider availability, limited service
options in some areas, and limited awareness from relevant Access Partner on
possible pathways and services.
Long waiting lists to access relevant services are a common issue,
with one family reporting:
It took a whole year to access supports, but everything was
booked out so my son's first plan was wasted. He used hardly any of his first plan
because of waiting list times!
Disability sector staff shortages were identified as one of the
contributing factors to delays in delivering services.
SDN Children's Services believes that 'the demand for ECEI support had
been underestimated and this has increased waiting lists for new children'.
As described by Deaf Services Queensland, issues of service delays are 'obviously
exacerbated through the tyranny of distance and limited options of specialist
providers within certain locations'.
The committee is concerned with widespread reports of delays in
accessing and receiving services for ECEI Participants with a Plan. This can
significantly impact on the success of therapies and the ability of Participants
to achieve optimal outcomes.
The committee noted that contributing factors to delays in accessing and
receiving services for Participants are part of a broader range of issues
across the Scheme, which include: overall disability staff shortages,
underestimation of the demand for support, and the limited options of
Costs of delivering services for service providers
Throughout the inquiry, ECEI service providers raised a number of issues
regarding additional burdens and costs associated with operating as an ECEI
service provider, the pricing of services and emerging gaps in funding.
Registration process and costs
Some service providers
expressed concerns about the registration process and the costs associated with
becoming an NDIS service provider.
The Commonwealth Ombudsman stated:
Many smaller service providers, and even some larger ones,
have also complained about the costs and administration associated with
registering with the NDIS, claiming the arrangements are more onerous than the
previous state requirements.
Speech Pathology Australia noted 'significant barriers to NDIS provider
registration to deliver ECEI supports in some states and territories'.
Occupational Therapy Australia reported that 'The NDIA's apparent
inability to engage meaningfully with service providers, and the difficulties
involved in navigating the NDIA website, act as disincentives to registration
as an NDIS provider'.
This has led to some services providers indicating they will not
register as an NDIS provider and may mean that only larger service providers
will remain in the market; reducing supply, decreasing competition and limiting
choices for families.
For example, a small service provider explained:
To register for NDIS Early Childhood Supports as a new
Provider is overly onerous; particularly for sole traders and small
organisations [...] I need to make a business decision about whether I can absorb
the costs associated with registration for NDIS. It is difficult to do this
when I can't determine roughly what these costs will be. Many of my colleagues
have decided not to register as the process is too onerous.
Speech Pathology Australia anticipates unmet need for speech pathology
ECEI services unless issues with provider registration are addressed.
The Dietitians Association of Australia drew the committee's attention
to the issue of the exclusion of Accredited Practising Dietitians (APDs) from
the Early Supports for Early Intervention Professional Registration Group.
recommended streamlining the registration process for providers.
Submitters raised concerns about the pricing structure used by the NDIS.
Significant new costs, including organisational overheads, are not reflected in
the NDIS pricing structure.
The Victorian Autism Specific Early Learning and Care Centre noted that
the NDIS Price Guide rates are often inadequate to cover the true costs of
quality service provision as 'they do not allow for the necessary overheads of
a well-coordinated (transdisciplinary) service'.
Similarly, Noah's Ark Inc argued:
The pricing structures being used by the NDIS are not
realistic in a number of areas, including organisational overheads. There are
significant new costs being introduced under the NDIS, including for marketing,
administration (e.g. highly complex financial processes) and IT systems.
The Cora Barclay Centre reported absorbing significantly increased
Under the NDIS, most of the very substantial burden of
administration is borne by service providers and families/participants, not by
Ms Dee Hofman-Nicholls, Director at Enhanced Health Therapy Services,
described the situation:
[...] for every one clinician we have on the ground we need a
0.6 FTE to support the administration costs of NDIA, which are exorbitant.
Effectively, for $175.57 we're paying two people's wages, not just one person's.
When the new price guide came out with no increase to therapy cost because 'you
are paid quite well,' it was quite insulting, because we aren't lining our
pockets. There are actual costs to administering the scheme. A lot of costs
aren't being billed onto the client.
As a consequence, Mrs Hofman-Nicholls concluded that small businesses
will stop operating:
Long term, small business will not be able to play in this
field and it will return to what we had: several big service providers with
long waiting lists and reduced or very little choice and control. There are
some very, very, very fatal flaws that will affect small business continuing in
Non-attendance at appointments
Occupational Therapy Australia and other submitters
reported that service providers are financially disadvantaged by clients who
fail to keep appointments despite some recent adjustments to arrangements that
partially compensate providers for non-attendance.
Until 30 June 2017, the NDIS price policy prohibited cancellation
charges. The policy was amended, and from 1 July 2017, the NDIA advised that:
Providers may charge for up to 2 participant cancellations
for therapeutic supports per annum. Each cancellation charge must be for no
more than 2 hours of support, and may only be applied where the participant has
failed to give 24 hours' notice.
Noah's Ark Inc noted that the NDIS rule on cancellation has been
modified but considers that it is not enough for service providers supporting
Young children, as is generally understood in the community,
become ill more quickly and more frequently than older children and adults. As
a result, the cancellations policy has a more adverse effect on service
providers supporting young children.
According to Occupational Therapy Australia, the lack of compensation
for cancellations is a contributing factor to providers not being able to have
a reliable income and ultimately leaving the sector, especially in regional,
rural and remote areas.
Peer and group therapy
Pricing guidelines also impacted the provision of peer and group therapy
services. Occupational Therapy Australia told the committee that:
The NDIS is currently not providing funding options for young
children to attend small social group therapy. Currently, group therapy is
funded at a rate that is not viable for clinics to implement, with rigid
therapist to child ratios that do not take into account the needs of the child.
Some submitters argued that changes to the NDIS Price Guide are needed
to reflect the costs of providing peer therapy to children with developmental
disabilities who are transitioning from individual to group therapy.
The evidence received to date about the registration process suggests
that the current system is not operating as well and effectively as it should
be. The committee also noted the issues around increased administration costs
borne by providers and pricing issues. All these issues are threatening the sustainability
of providers, especially sole traders and small organisations to operate in the
NDIS environment. This has the potential to further limit choices for Participants
and further extend delays in accessing and receiving services.
The committee acknowledges that, in response to the wide range of issues
raised in the FY2017–18 Price Review, the NDIA has commissioned an Independent
Pricing Review, which is currently being undertaken by McKinsey & Company.
The committee understands that the Review will deliver its Final Report by the
end of 2017.
The committee also notes finding 8.1 of the Productivity Commission in
its recently released Study Report on NDIS Costs, which states that 'the
benefits of the NDIS will not be fully realised if the Agency continues with
its current pricing approach'.
Once released, the committee will consider the Independent Pricing
Review report within the broader context of the NDIS market readiness.
Provision of ECEI services in rural and remote areas
Accessing and delivering services in rural and remote areas presents
some challenging issues. Issues raised by service providers include lack of
funding for travel and use of innovative technologies to deliver appropriate
Transport costs for service providers to deliver services in rural and
remote areas are high. Dr Jennifer Fitzgerald, CEO, Scope Australia described the
Transport, particularly for us in rural and regional Victoria,
is a major problem. We are unable to bill between services. We can bill for the
first 40 minutes of the day. Our practitioners see approximately five or six
children a day, if they're out on the road, particularly in rural and regional
Victoria. All of that time and the actual cost of the vehicle—mileage cost,
depreciation, maintenance and purchase—is unfunded.
Mrs Amanda Mather from Hear and Say reported that, due to lack of
specialist services in rural and remote communities, Hear and Say has to travel
to adequately support families and noted that 'the travel allowances that are
currently provided for in the NDIS are inadequate and not satisfactory for the
size and nature of Queensland'.
Deaf Services Queensland described travel as being the 'single most
complex issue in terms of adequate funding to provide support, particularly in
locations where the Participant does not live close to services'.
Their submission highlighted that 'the $1000 a year limit on travel for
therapists (across all therapy support delivered) does not provide fair and
equitable access to supports and services for clients living in more regional
areas or clients who are financially challenged and don't have access to
transport to attend sessions'.
Similarly, Speech Pathology Australia highlighted that the limits for
payment for provider travel can restrict access to specialised supports:
Rulings regarding NDIS payment for travel by providers
further restricts access to these specialised speech pathology services to NDIS
Participants who need them. Defining strict limits for payment for provider
travel in all Participants plans and not allowing flexibility in travel
expenses for individual Participants means that children who required the
services of a speech pathologist with specialised expertise may not be viable
to purchase within the parameters of the funded plan if that practitioner is located
a significant distance away from the child.
Vision Australia believes it is unfair for families and service
providers to be put in a situation where they are required to draw down on Participants'
support budgets for purposes of travel as this may impede them receiving
At a public hearing in Melbourne, Mr Scott Jacobs from Vision Australia
When you do bill for travel, it comes out of the support
budget for the participants. In theory the participant is given an allocation
within that budget that is intended for travel. It's not separated out, and the
justification or rationale that leads to how much travel might be included in
that support budget is not ever clear. If you have multiple providers billing
travel, the limits are different for adults and children, but you are drawing
down on what could potentially be your support budget for service delivery,
which from a provider perspective is an ethical quandary and is not a
particularly pleasant one. What would be ideal would be to have a specific
limited budget for provider travel to be able to have the access that doesn't
touch the support budget for families.
Many submitters recommended allocation of additional funding, on top of
the loading currently provided, for travel to address the significant
challenges for families and service providers in rural and remote areas.
AMAZE submitted that emerging research supports the efficacy of delivery
of therapeutic services to remote locations via videoconferencing facilities.
Speech Pathology Australia recommended greater use of videoconferencing
to communicate with clients and families living in rural and remote areas.
Similarly, Connect and Relate for Autism Inc argued that a telehealth service
model can significantly reduce the demands and costs associated with families
needing to travel long distances to access services.
However, Early Childhood Intervention Australia reported 'inadequate
resourcing of technology to enable collaboration and access to remote areas and
consultations' and recommended 'funding for ICT infrastructure and technology
solutions to enable case-conferencing, skype/online consultations and chat
rooms and e-referral'.
Lifestart suggested that 'investment in the use of technology for some
ECEI service provision is one way to resolve accessibility issues in some rural
and remote areas'.
Hear and Say also recommended 'improving funding for technology to assist with
access to tele practice services.
Similarly, AMAZE called for the Australian Government and the NDIA to consider 'innovative
service delivery methods such as telehealth models to mitigate potential market
Overall, Participants recommended a review of costs of service
provision in regional, rural and remote areas.
The committee understands there can be significant additional costs to
deliver services in rural and remote areas, including costs associated with
travel. The committee noted that the new NDIA Price Guide, introduced on 1 July
2017, incorporates a series of changes, including an increased price loading to
apply for the delivery of supports to Participants in remote and very remote
parts of Australia.
However, it appears that the issue of travel costs remains a significant cause
of concern for services providers. The committee believes it is too early to
evaluate the impact of the recently introduced increased price loading for
delivery of supports in remote areas.
The committee notes with interest the call for a greater use of
technology, especially videoconferencing for delivering services in rural and
remote Australia. Submitters identified videoconferencing as an efficient and
cost effective way to deliver some types of services. The committee believes
technological solutions to deliver services should be encouraged as long as the
quality of services is not compromised. The NDIA should, as part of progressing
its rural and remote strategy, investigates how it can better support Participants
and service providers to use technology.
The committee recommends the NDIA develop a strategy to foster greater
use of technology to deliver services in regional, rural and remote areas.
Workforce availability, remuneration and training
ECEI service providers expressed concerns around the availability of a suitably
qualified and experienced workforce.
Inadequate remuneration and lack of training and professional development
opportunities were identified by submitters
as major contributors to current staff shortages.
SDN Children's Services highlighted the inability for service providers
to recruit and retain staff due to the limited funding available under the ECEI
Early Childhood Intervention Australia Victoria/Tasmania raised concern
about funding constraints that 'will lead to the employment of graduates with
lower qualifications and/or less experience'.
Carers Australia stated that specialists are 'often in short supply,
especially when they may have more attractive employment conditions in the
Occupational Therapy Australia argued that the ECEI Approach should
ensure the viability of providers who work in a variety of capacities (as sole
providers, in multi-disciplinary private practices, as part of NGOs) 'by
recognising the costs of delivering services and ensuring these are offset by
National Disability Services and others
expressed concerns about the NDIS pricing model, which limits opportunities for
training and professional development. This could contribute to workforce
shortages in the future.
Noah's Ark Inc noted 'there is little indication that the NDIS costing
has considered the recruitment and training of new staff or the need to provide
careers for allied health professionals and teachers, who have other career
opportunities in health and education'.
Early Childhood Intervention Australia NSW/ACT expressed the view that 'the
ECEI Approach needs to assist with the mentoring of the future ECI workforce.
This has cost implications and the funding should support the development of
our future workforce'.
National Disability Services and others
recommended the development of a strategy for responding to skilled
Similarly AMAZE identified the need for 'a concentrated effort by Government to
stimulate growth in the skilled disability workforce'.
Workforce shortages are well documented. As described by the
Productivity Commission in its recent Study Report on NDIS costs,
the disability sector workforce will need to double and in some regions triple
or more over the transition period to meet demand. It is not surprising,
therefore, that this issue was raised in the context of this inquiry.
The committee received evidence that workforce remuneration, training
and professional development issues contribute to current challenges. The
committee believes these important issues warrant further work and analysis,
and be considered within the broader context of market and workforce readiness.
Navigation: Previous Page | Contents | Next Page