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It’s been a May of changes for group services, including some big shifts in the rules around Programs of Support (POS) outlined in the Pricing Arrangements update effective 5 May 2023.
Programs of Support are not new, but today they are used inconsistently across the sector. In short, a POS is a way of bundling up groups of supports into a discrete program. Not all service types can use a Program of Support model. The major benefit to providers is that services can be billed whether the person attends or not and this is also the major benefit to participants - giving some stability that the group billing arrangements will remain the same even if one person doesn’t attend in one particular week.
We often say about Programs of Support that they look like a great deal for providers, (more stability is always welcome, right?!) but there’s no such thing as a free lunch. Programs of Support are built with safeguards to ensure choice and control can still happen even where the usual Short Notice Cancellation rules don’t apply, and these changes maintain and boost those safeguards. Some of these new rules will substantially affect how a provider designs and offers Programs of Support, while some will be more system changes and checks.
Here are the biggest things you need to know about.
Increase in maximum Program of Support length
The maximum amount of time a POS can run has increased. Previously it was 12 weeks, and it’s been extended to six months. That’s a big change, although it comes with some requirements around reviewing the POS and some caps on how long a provider can bill if a person doesn’t turn up without notice and is uncontactable (see below). Overall, this change means that a provider can offer a much longer-term POS but will need to be alert about whether offering longer programs makes it look like they are attempting to capture clients.
Opportunity for review
One of the safeguards for participant choice and control is the new requirement around reviewing a POS. If a program is longer than 12 weeks, the provider must offer participants the chance to regularly review the POS. The NDIA has offered no guidance or prescription on what this review needs to look or feel like, so it’s up to providers to work out what works for the people they support. It may be a formal sit-down review, or it might form part of regular Support Planning processes, or it might be more informal using other engagement methods. There’s no perfect way to do it, but it’s a very good idea to document the result of these regular reviews.
A participant signing up to a six-month POS could have a negative impact on choice and control if they don’t know exactly what they are agreeing to. So, the Code of Conduct requirements for providers to act with integrity, honesty and transparency may come into play, if it’s deemed that a person was tied into a long-term POS with the aim of reducing flexibility.
Unplanned Exit
Another major safeguard is a cap on the number of weeks a provider can bill a person for non-attendance at a POS. A key component of the model is that a provider can bill whether the person attends or not, but this is moderated in the new rules. If a person is a no-show to a POS (with no communication that they won’t be attending), the provider can bill a maximum of four consecutive weeks before the person is deemed to be an Unplanned Exit of the Program and their plan can be no longer billed. Ideally, the person would be in touch some time over those weeks to clarify whether they still want to be part of the program or whether they are giving their notice period to exit. And of course, if a person goes completely AWOL for several weeks, a provider should be much more concerned about their welfare and safety than whether they are going to bill them for this week’s group service - internal processes about Duty of Care checks should swing into action.
Weighing up a POS model
Ultimately, a POS model is optional for all parties - unlike the move to the apportioning pricing model, providers can decide when and if they use a POS approach. There’s pluses and minuses either way. It certainly gives more security for providers - being able to bill whether the person attends or not means that rostering and planning can be easier. But a provider also must have a Program of Support Agreement in place, build agreed outcomes into their programs, and offer chances for the person to review their POS. So, using the model requires some initial and ongoing work from the provider.
For participants, there are risks to an NDIS plan being used quicker, (if services are being billed even when a person didn’t attend) but there are also those rules in place around regularly reviewing longer Programs, Unplanned Exits and notice periods to protect people. The stability will work for some, and won’t work for others, but the NDIA won’t force anyone to have a POS model for their supports if they don’t want it. Programs of Support remain optional.
We run some online workshops about the Program of Support model, as well as a self-paced eLearning module that has been updated with these new rules. Ultimately there are good parts and less good parts of a POS model, and there’s some changes to make in the back end of a provider’s approaches and systems, and participants must agree to it. So, it’s something that should be discussed by all parties to find a happy medium.
