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I have recently started as a Plan Manager, and I have begun seeing long, multi-hour shifts being billed at a higher hourly rate than I would have expected. This is eating up the person’s plan quicker than we originally budgeted for. When I queried this with the provider, they said, “it’s a boundary shift so the whole thing is billed at the higher rate”. I have never heard of a boundary shift before, what is it? And is it legit?
Ah, boundary shifts - one of those billing practices stuck in a dark corner of the Pricing Arrangements and Price Limits (PAPL) but used so frequently. It should really be more visible than buried on page 16, especially given many providers rely on it to remain compliant with Award conditions. You might also hear them called shoulder shifts - which sounds more like something my physio would prescribe.
What is a boundary shift?
A boundary shift is when a single shift crosses the boundary between Daytime Support, Evening Support, and Night Support. For the purposes of NDIS service delivery:
- a support delivered between 6am and 8pm on a weekday is considered to be a Daytime Support
- a support delivered between 8pm and midnight on a weekday is considered to be an Evening Support
- a support delivered after midnight is considered to be a Night Support
- There are other rules for sleepovers which we won’t get into here
Each of these supports attract a different hourly rate, with a higher hourly rate for Night Support than for Evening Support, and a higher hourly rate for Evening Support than Daytime Support. This is broadly to reflect the penalty rates in the Award.
Billing for boundary shifts
The PAPL states that if a single shift (i.e. the same worker delivering the support) crosses one of these boundaries, the whole shift can be billed at the higher hourly rate. For example:
A worker delivers a support billed from Assistance with Daily Living. The shift runs 6pm to 10pm, thereby crossing the boundary between Daytime Support and Evening Support. As long as the same worker delivers this whole shift, the provider can bill 4 hours at the Evening Support rate rather than 6pm to 8pm billed at the Daytime Support rate + 8pm to 10pm at the Evening Support rate.
Importantly the eligibility for billing boundary shifts depends on the same worker delivering the support, rather than the same Item Number being used. For example, maybe the shift is actually 6pm to 8:30pm for Assistance with Social Participation then 8:30pm to 10pm for Assistance with Self Care. As long as the same worker is delivering the shift, it’s fine to bill the whole 6pm to 10pm as a boundary shift.
So going back to the original question: the provider is correct, it’s permissible to bill the whole 4-hour shift at the higher rate as the shift crosses the boundary. But (there’s always a but)...
It’s not compulsory
Billing for boundary shifts is not required by the NDIA, not uniform and their use is varied between providers and workers. Some organisations and rostering systems default to this billing practice automatically, others can’t cope with it or require such an admin-intensive workaround that the providers don’t think it’s worth the time. It’s most commonly used by providers delivering 24/7 support where long, stable, frequent shifts are happening. There is a general rule in NDIS billing where if the provider bills a higher rate, they need to be paying their worker a higher rate as well. But whether a provider is legally obligated to pay their worker a higher rate when billing a boundary shift is dependent on the specifics of how the worker is engaged under Award conditions, or an Enterprise Bargaining Agreement, or another method altogether.
And of course, the person has to agree to be billed at the higher rate for the whole shift. As a Plan Manager, it’s a good idea for you to support the person to query whether a provider will be billing for boundary shifts when they are investigating quotes and proposed service costs. Your expertise might also help the person to negotiate with the provider whether boundary shifts will or won’t be billed, to assist with squeezing more value from their NDIS Plan and budgeting for the life of the Plan. All these will help with that faster-than-expected plan expenditure the person you support is experiencing now.
