Ask DSC: Programs of Support and SIL

I’m a small SIL provider and, like many providers, I’ve been struggling financially since Covid started. I rang the 1800 Provider Support phone number to ask about how I should manage a vacancy. They said that I could just put all my SIL supports through as Programs of Support (whatever that is?), and I would be able to bill like it was block funding. Is this true? If so, it would really help.

I feel your desperation, and I suspect you’re not alone. But if it sounds too good to be true, then it usually is. While the NDIA Provider Support team’s solution sounds great for providers (possibly not so good for participants, but more on that later), the devil is in the details.

This may be the first time you’ve heard of a Program of Support (POS). A POS is a way of bundling some types of NDIS supports into a discrete, time-bound program where the short-notice cancellation rules listed in the Pricing Arrangements don’t apply. There are several requirements to use a POS:

• It’s only available for the supports listed on page 28 of the Pricing Arrangements document. Specifically, group-based supports delivered under Assistance in Shared Living Arrangement – Supported Independent Living, Assistance with Social, Economic and Community Participation Support (including Supports in Employment), or any Capacity Building support.
• It can only be used for group-based supports (i.e., those delivered to more than one person), except for services delivered under Early Intervention Supports for Early Childhood.
• Every POS has a maximum length of 12 weeks. There is no minimum length.
• A provider must enter into a POS Agreement with each participant that specifies the length, the exit rules (a person can exit with only two weeks’ notice), and the program’s intended outcomes.
• Most importantly, the participant must agree to using a POS approach for these supports.

In exchange for meeting these requirements, the provider can bill for services delivered in a POS, whether or not the person attends or accesses those services. A POS doesn’t mean a provider has to bill if the person doesn’t attend – it just means that they can bill. There are also other, more technical rules and requirements that we won’t go into here (they are on page 29 of the Pricing Arrangements document).

 So yes, supports delivered under Assistance in Shared Living Arrangement – Supported Independent Living are eligible to be delivered under a Program of Support model, but a POS is not a magic bullet. It’s not block funding. It doesn’t overrule other requirements like good vacancy management (the SIL Operational Guidelines highlights that you can’t increase what you bill each person to cover vacancy costs, so you still need a good process for this). And you can’t pre-claim for services delivered in a POS (i.e., you still need to wait until you’ve delivered the support before you claim).

The maximum length of a POS matters when deciding whether a POS is right for you. Consider that the maximum length of a POS is 12 weeks and that anyone can exit a POS (without penalty) by giving a maximum of two weeks’ notice. So, the safeguard of being able to bill, whether the person attends or not, is really only two weeks. The additional administrative component of agreeing and completing a new POS Agreement every 12 weeks (at least) means this option won’t suit everyone.

The jury is also out on whether POSs offer great outcomes for participants. It will work for some: providers gain assurance from the stability of Programs of Support and participants can benefit from this, but there is also a chance that a person’s plan funds may be exhausted sooner than when not using a POS. Some participants might consider that tying themselves into a POS offers them less flexibility than they might have otherwise, so they may not agree to use it for billing.

Programs of Support can be fantastic. When used well, they can offer additional assurance for participants and providers that a service will go ahead. But they also come with implications for people’s NDIS plans, provider quality systems, and service delivery. There’s no such thing as a free lunch.

A POS isn’t going to be a perfect fit for every participant, provider, and situation. No matter how much you and your business are struggling with the impact of Covid, it’s worth thinking critically about whether the POS approach is the right fit for your organisation and the people you support.