This Appendix contains recommendations made by the the National Disability Insurance Scheme (NDIS) Scheme Actuary in the 2020-21 Annual Financial Sustainability Report (AFSR), released publicly in October 2021.
9. Recommendations
The AFSR is required, to include “a discussion of the key risks and issues identified and, where these have an adverse impact on financial sustainability, recommendations designed to manage the risks or address the issues”. This section sets out the recommendations arising from the analysis undertaken in development of this report, that are intended to manage identified risks and achieve greater certainty in relation to the long term financial sustainability of the Scheme.
Embed insurance principles in NDIS culture and communications
The financial sustainability of the NDIS is central in the NDIS Act and a key expectation outlined in the Ministerial Council’s Statement of Strategic Guidance for the NDIA’s Board. The NDIA is committed to deliver the Scheme in line with the requirements of the NDIS Act and within a sustainable level of funding.
To meet this commitment, the NDIA’s financial responsibilities and associated insurance principles must be clearly understood by all NDIA stakeholders (participants, disability groups, NDIA staff, partners and other stakeholders) and embedded into the long-term future of the Scheme. NDIA initiatives, including those recommended below, must be underpinned with communications that emphasise the Scheme’s intent and its insurance principles.
Recommendation 1: The NDIA should ensure that NDIS insurance principles are embedded in its strategic communications with participants, disability groups, staff, partners and other stakeholders.
Focussing on participant outcomes
The NDIA needs to be effective in supporting participants to achieve positive outcomes by ensuring support costs are expended, as much as possible on early intervention enabling participants to achieve improved economic and social participation outcomes. This is central to the purpose of the NDIS, and will have longer term benefits for financial sustainability via reducing future reliance on funded supports over participants’ lifetimes.
Whilst the agency is assisting participants to set goals and achieve outcomes, further work is required to:
Understand the supports available that are evidence-based and have proven to be effective for other participants
Monitor a participant’s progress towards significant outcomes
Measure the impact of different types of support or “pathways to outcomes”.
Recommendation 2: The NDIA should continue work on prioritising, implementing and measuring the impact of initiatives that aim to improve participant outcomes.
A number of projects are in progress and should be a priority for completion in the coming year:
Increasing the capacity and capability of NDIA staff and partners to find, generate and use evidence for decision-making through a range of activities led by the Research and Evaluation Branch
Developing “supported decision guides” to help participants make informed, evidence-based choices
Completing and releasing the “Participants Like Me” interactive web tool, for participants to access information on the supports and pathways that have helped other participants to reach their goals
Providing participants with support to make more structured goals, through additional fields in the CRM, to enable them to clearly communicate their expectations to providers and other people supporting them.
Recommendation 3: The NDIA should prioritise the completion of existing projects that support participants to make and communicate informed, evidence-based decisions.
The NDIA should continue to focus its research on the evidence base for a range of clinical and non-clinical supports and publish these in accessible formats. In particular, the provision of early intervention supports should benefit a participant by reducing their future need for disability supports. The NDIA can facilitate better lifetime outcomes whilst achieving longterm cost reductions by supporting participants with information on evidence-based early intervention supports.
Recommendation 4: The NDIA should continue to make progress in reviewing, developing and communicating the evidence base for different forms of early intervention supports.
Given its scale and market influence, the Agency could develop further initiatives to foster innovation in the delivery of supports in the market, thereby increasing choice and control for participants. This may also involve increasing the awareness of different service delivery methods, such as therapy through online platforms, to assist participants who have difficulty finding the ‘right’ providers in their area or who are in remote locations. Another option is encouraging providers to invest in new technologies, support types and markets, e.g. providers who have the technologies (or would be able to invest in new technologies) to enter new markets and/or expand their support type offerings. In general, the Agency could focus on empowering and enabling participants to select the support and delivery channels that best suit them, their lifestyle and time commitments, and then request these from providers.
Recommendation 5: The NDIA should continue to develop initiatives that provide participants with a greater range of service options to suit their own needs and circumstances. This includes innovations in market development and provider service delivery.
Consistent and equitable agency decision-making
Given the baseline cost projections, and related uncertainty described in this report, it is imperative that NDIA aims to improve the certainty of the Scheme’s costs over the long-term, through improvements to the consistency and equity of decision-making and the quality of information provided from and to prospective participants and participants.
In July 2021 the Commonwealth and State/Territory disability ministers agreed to work in partnership with those with lived disability experience to co-design a person-centred assessment approach that delivers consistency and equity in access and planning outcomes. This is consistent with the NDIS Act and its insurance principles.
A foundational component of this equity and consistency is an approach to assessment of function which achieves robust and consistent assessment of participants’ functional capacity, as well as their environmental and personal circumstances (to the extent that these circumstances are relevant to determining reasonable and necessary supports for participants).
Recommendation 6: The NDIA should, consistent with the NDIS Act, actively pursue via codesign an assessment approach which measures functional capacity in line with relevant chapters of the International Classification of Functioning, Disability and Health, and which incorporates environmental and personal factors that are salient to the determination of reasonable and necessary supports.
Recommendation 7: The NDIA should co-design new guidance materials with medical and allied health practitioners, to ensure more consistent evidence is received and that the NDIA makes more consistent decisions on access requests and the development of plan budgets.
Recommendation 8: The NDIA should implement stronger controls on the type and quality of evidence accepted to ensure consistent minimum standards are adopted across the NDIA’s access and planning functions.
The number of exits from the Scheme continues to be below expected long-term levels, due to challenges in measuring the benefit of early intervention and the continuing need for Scheme supports.
Recommendation 9: The NDIA should reassess eligibility for participants who entered through early intervention as part of the normal course of business, whilst providing reassurance to those who exit the Scheme that it will be available to them in the future should their circumstances change.
Recommendation 10: The NDIA should ensure that the co-designed assessment approach is appropriate for eligibility reassessments in addition to access and planning decisions, for instances where it is appropriate to undertake a reassessment in line with the purposes of the Scheme. This would provide consistency in Scheme entry and exit processes.
Within the current CRM system, the date when disability is acquired is often incomplete or not reliably captured. This limits the ability to analyse new incidence of non-congenital disabilities, which means projections of new entrants cannot be reliably modelled using date of disability acquired.
As identified at the previous review, and discussed in Section 5.3 of this report, the number of new participants has been significantly higher than previously assumed, in particular in geographic areas which phased into the Scheme at least three years earlier. Uncertainty exists as to the degree to which this unfavourable observed experience represents true new incidence”, “previously unmet need” or expansion of eligibility.
Recommendation 11: The NDIA should undertake further detailed analysis to better understand the drivers of higher than expected new entrants, to increase confidence in long term assumed new incidence rates.
Scheme scope and coverage
There needs to be continued focus on the National Disability Strategy and the Applied Principles and Tables of Support (APTOS) to ensure that planners and participants systematically identify and access supports provided by other systems. The NDIA must develop proactive strategic responses to incentivise the continuation of these supports. This would include support for plan implementation to allow participants to connect with alternative services when needed.
Recommendation 12: The NDIA should focus on plan development and implementation processes to systematically ensure that participants identify and are supported to access appropriate supports from other service systems.
The NDIA should be proactive in identifying trends in AAT matters that have the potential to significantly impact the ongoing financial sustainability of the Scheme. In response to such trends the NDIA should ensure that there is clarity on Agency policies and in operational guidelines. It is anticipated that the Agency’s focus on improving the consistency, equity and transparency of its decisions should result in fewer AAT cases over time.
Recommendation 13: The NDIA should continue to focus on risks to financial sustainability associated with mainstream interfaces and themes from AAT cases.
Improving operational processes
Quality assurance reviews demonstrate significant improvements over the past year, including more comprehensive documenting of plan decisions in participant records. It is important for the Agency to continue undertaking risk based quality assurance reviews to better understand Scheme experience and continue to improve processes.
Recommendation 14: The NDIA should ensure that the results of ongoing quality assurance reviews are embedded as operational improvements.
The quality assurance reviews highlighted possible improvements in ICT system controls to support accurate decision-making. In particular, the Agency’s CRM does not fully support end-to-end participant planning, or referrals to higher delegates. It also does not enforce mandatory requirements in the Operational guidelines such as recording interactions, relying on Agency staff to comply with these policies and increasing the scope for manual errors or omissions.
The implementation of ACE provides an opportunity to ensure that consistent controls are built into the system to better support the decision making process. The incorporation of business intelligence around key business processes would also assist in ensuring more effective and consistent decision making.
Recommendation 15: The NDIA should embed improved controls into current and future CRM to ACE system changes to improve the integrity of the participant planning process.
The NDIA’s documentary evidence requirements are lower for services rendered to participants by non-registered suppliers. This reduces the NDIA’s ability to identify fraudulent or “sharp” practices, for example providers charging for supports that were not provided, charging multiple times for the same service, or charging unreasonable amounts. The Agency’s fraud detection efforts would be strengthened through consistent documentation requirements for services rendered, irrespective of a supplier’s registration status.
Recommendation 16: The NDIA should strengthen its ability to detect fraud through increasing the supporting data and documentation requirements for payments to nonregistered suppliers.