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The new price guide has been released- and it isn’t all good news. Let’s unpack what this means for Supported Independent Living (SIL) providers.
The rates in SIL quotes are now capped and will be in the future.
For the first time, there are now price caps for SIL in the Price Guide. These rates are not finalised, indexing will be determined once the Fair Work Commission wage review is completed. There will also be a new SIL Provider Pack released in the next few weeks with more information.
Any existing quotes approved with rates higher than the new capped prices will continue for the remaining period of their 12-month plan. After that the new capped rates apply. Any pending quotes will be processed with the new capped rates.
So, if you have a SIL service booking approved at higher rates than the ones included in the price guide, you need to start preparing now for a potentially significant reduction in the person’s next plan.
This may have substantial financial implications for providers who are already working in a confusing and messy system. And with COVID-19 already pushing the costs of supporting people at home into the marginal arena, this couldn’t have come at a worse time.
Prior to the NDIS rollout, Supported Accommodation providers played many roles for a Participant in a system that didn’t necessarily fund everything that was needed. The NDIS now provides separate funding for Support Coordination, Capacity Building supports and services, but untangling the services provided within SIL from those that should be funded through other parts of the plan is proving to be challenging for providers. For some, this is a significant philosophical and operational jump. The plan utilisation stats in the latest quarterly report show that potentially SIL providers are still stepping in where other services could now assist.
The SIL price guide capping may have thrust providers forward into this new world in a big way. If your costings weren’t clear or didn’t work before, things just got worse.
Indexing will no longer be added into the SIL quote.
The NDIA Supported Independent Living Provider information page notes the following.
“The rate limit used for SIL will be increased only when the relevant Assistance with Daily Living price limits are increased – in accordance with the pricing review decisions for the impact of the Fair Work Commission Minimum Wage and Award decisions and Equal Remuneration Order increases. There will be no other indexation increases applied”.
In some cases, this may mean that when the plan gets reviewed, you will be able to increase to new rates. But if the Participant has a multi-year plan, or your quote is accepted just before a price increase, your costings might blow if you are required to implement a wage increase.
Plan automatic extensions and SIL service bookings
The new Price Guide also says:
“When we have been unable to undertake a plan review by the time a participant’s current plan ends, it will be automatically extended by 365 days.”
For providers that have been in that excruciating holding pattern with no funding between two plans, this seems to be a huge win. But then we read on…
“This creates a discrepancy between service bookings and the plan, because the SIL service booking displays a higher amount than the plan amount. SIL providers should claim at the amount for the original (non-extended) plan and accepted quote.”
Translated into terms we can understand, this means that the Provider should not claim any more than they were claiming prior to the extension. If you can divide the service booking by 53 and get more than you were claiming before…. don’t, even if there has been a price increase attributed since your last quote.
The vital question here is what does “unable to undertake a plan review” look like? Is it a legitimate attempt to convene a meeting and determine a change in supports? Or a quick letter posted to a last known address? When we factor in the lack of indexing, the new price caps and the significant pressure being felt by SIL providers lately, this again could have massive financial implications.
The roster of care should be seen and approved by the participant (or their nominee)
Another notable change on the NDIS Supported Independent Living Information page is the requirement that Participants and/or nominee have had an opportunity to see and provide input into the roster of care. This is a great step forward in relation to strengthening relationships and consultation processes but may have significant implications from a privacy perspective as the roster of care is competed for all of the Participants living in the house, not just one individual. Navigating this correctly will be vital from a quality and safeguards perspective.
We have been just as frustrated as anyone with the changes to the SIL quoting process recently. The introduction of counter-offers that mostly disregarded the provider quotes, the disappearance of indexation and drip-fed information in the form of emails and whispers. And we have been desperate for more details. But I wonder if this has just become a case of being careful what you wish for? Because this news isn’t necessarily going to do wonders for providers 20-21 budgetary preparations, which this late in the financial year were probably almost finalised.
