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The NDIA have just released the juiciest paper on Support Coordination to date, in a discussion paper that forms the basis of a review of the Support Coordination service model, exploring five key topics:
- Inclusion of support coordination in participant plans
- Understanding the role of a support coordinator
- Quality of support coordination
- Capacity building for decision making
- Conflict of interest.
Some of you may remember that the NDIA commenced a review of intermediaries services (Support Coordination and Plan Management) around three years ago. This review was supposed to result in practice guides for both supports, though these were never released.
The announcement of this new review is a clear indication that the NDIA is reconsidering their approach to Support Coordination, including the scope of the role and how and when it should be funded. There are 21 specific questions the review asks providers to explore in their submissions, which are open until 13 September (full details at the end of the article).
The full discussion paper can be found here and our summary is below:
Inclusion of Support Coordination in participant plans
For the first time, this paper reveals some interesting data on the split of funding by Support Coordination levels. Of participants who are claiming for Support Coordination, the split is:
- Level 1 (Support Connection): 2%
- Level 2 (Coordination of Supports): 98%
- Level 3: (Specialist Support Coordination): 4%
Thus confirming what we pretty much already knew- that almost all Support Coordination is happening at Level 2 (Coordination of Supports). Note that the numbers here don’t add up to 100% because some participants receive funding at more than one level.
The paper also reveals the rates of Support Coordination funding by age group and primary disability:
Another figure that stood out for us was the average funding for a participant who is agency-managed or plan-managed: 5 hours of support coordination per month (ie. 60 hours per year). While there are undoubtedly many participants funded at this level, it seems remarkably high as an average. In every Support Coordination Intensive we run, we take a poll on the average funding in plans and the answer is very consistently 24-48 hours per year. We’d question why self managers have been excluded from the statistic above and would love to see the NDIA’s data in a bit more detail.
The key data point the NDIA are highlighting in this review is the impact of Support Coordination on plan utilisation. Current plan utilisation for participants with Support Coordination in their plans is sitting at 66%, compared to 67% for participants not funded for Support Coordination, which on the surface does not look good.
This is tricky data to interpret though because it does not compare apples with apples. Firstly, we know that participants most likely to experience barriers in connecting to supports are those funded for Support Coordination. So what does success look like in this context? Do we expect Support Coordinators simply to support people experiencing greater barriers to spend their plans on par with participants without those barriers? Or would we expect people with this support to exceed those levels?
Secondly, the table compares people with or without Support Coordination in their plans, which is not the same thing as comparing people with or without a Support Coordinator. Only 69% of Support Coordination funds that are put in plans are spent, meaning that this data potentially misrepresents what is likely a tale of two stories: a group of people with very low or no utilisation (those who did not engage a Support Coordinator) and a group of people with above average utilisation (those who did).
It would have been a lot more interesting for the NDIA to compare the outcomes of people funded for Support Coordination (ie. identified as having increased barriers to accessing supports) by whether or not they actually engaged a Support Coordinator.
The NDIA also provide tables comparing plan utilisation for people with and without Support Coordination by disability type, age and state. These tables show very little to no difference between plan utilisation rates for people with or without Support Coordination funding across all cohorts. Again, this is not to say that Support Coordination has no impact, since it’s impossible to isolate its impact when the data is lumped in with a large group of people with high barriers to access and no Support Coordinator in their life.
Understanding the role of a Support Coordinator
The role of Support Coordinators is not well understood by providers, participants, families, LACs, Support Coordinators and even the NDIA itself. This review appears to be looking to clarify the role boundaries, asking for input in three specific areas:
- what functions/tasks a Support Coordination should perform
- whether participants would benefit from more targeted support coordination for specific plan goals related to education, accommodation and employment
- whether Plan Management and Support Coordination could be “more closely aligned”
Quality of Support Coordination & Value for money
Let’s start at the part you’re probably most interest in: pricing. And on this topic, there is good news and bad news. The paper states:
The hourly price limit for level 2 support coordination is higher than that for the newly introduced psychosocial recovery coach support. The NDIA is considering how to better align the price of support coordination with participant outcomes and the price of other Scheme supports.
This seems to strongly imply that the NDIA are exploring a reduction in the price of Support Coordination to bring it closer to the price limit for Recovery Coaching. That’s (quite obviously) the bad news. It’s also an interesting way to address the pricing discrepancy, by lowering the price of the older support instead of increasing the price of the new one.
The good news is that they are exploring more outcomes-focused pricing approaches, which, if done well, could encourage innovation in service delivery and incentivise outcomes over output. Examples of outcomes include sourcing appropriate accommodation or employment opportunities. It will be very interesting to see how participants and providers respond to this suggestion.
On the question of quality, the NDIA are exploring whether there is a need for minimum qualifications, accreditations or measures. This is somewhat perplexing, given registration requirements are the responsibility of the NDIS Quality & Safeguards Commission. It is not not clear how this submission question sits with the NDIA's remit or feeds into the NDIS Commission's registration requirements.
Building capacity for decision making
The paper is also asking some critical questions about supported decision making and advocacy. We know many Support Coordinators and participants will be eager to read the findings of this paper that asks questions around how Support Coordinators can best build capacity and support people to make their own decisions and where exactly the role boundary lies in relation to advocacy.
Conflict of interest
Picking up on the Tune Review and IAC recommendations for stronger guidance around provider conflict of interest (providing both Support Coordination and other supports to the same person), the review paper explores providers’ current obligations and asks whether stronger regulation is required.
The paper reveals that on average, just under half (41%) of participants currently receive their Support Coordination from a provider who also provides them with other supports, with the most likely combination being Supported Independent Living (SIL) and Support Coordination. The Joint Standing Committee’s review of SIL recommended that a separation of these supports be enforced “as a matter of urgency” so it is encouraging to see the NDIA seriously exploring the recommendation that has now come out of three major independent reviews.
Submissions
Feedback should be submitted via email to [email protected] by 11.59 pm AWST Sunday 13 September 2020.
Consultation with participants, families, carers and nominees will be through virtual community events, focus groups, and one-on-one interviews and will be advertised on the NDIS website.
The review includes specific questions for the public to answer (though naturally you do not have to attempt to answer them all). The questions are:
Inclusion of support coordination in plans
1. What factors should be considered when determining if, when and for how long support coordination should be funded in an NDIS participant’s plan?
2. Should the current three level structure of support coordination be retained or changed?
3. How should support coordination interact with other NDIS supports? For example, local area coordinators, community connectors, liaison officers and recovery coaches?
4. How should support coordination interact with and complement existing mainstream services?
5. What can or should be done to address the level of utilisation of support coordination in plans; and is this any different to general issues of utilisation?
Role of support coordination
6. What functions should a support coordinator perform? Are there tasks that a support coordinator should not do?
7. Is there evidence that participants with specific plan goals related to education, accommodation and employment would benefit from more targeted support coordination services to achieve these outcomes?
8. How could plan management and support coordination be more closely aligned and what would the potential benefits and risks be?
Quality of Support Coordination
9. Should there be minimum qualification requirements or industry accreditation in place for support coordinators? If so, what might be applicable?
10. How can the effectiveness of support coordination be measured and demonstrated?
11. Are there emerging examples of good practice and innovation in support coordination?
12. Are the levels and relativities in the NDIA price limits across different services including support coordination working effectively in the interests of participants and a sustainable, innovative market?
13. Should support coordination pricing be determined, at least in part, based on progression of participant goals and outcomes, and how might this work?
Building capacity for decision making
14. How can a support coordinator assist a participant to make informed decisions and choices about their disability supports? What are the challenges?
15. How does a support coordinator build a participant’s independence rather than reliance? Should support coordination pricing be determined, at least in part, based on building a participant’s capacity for decision making to become more independent?
16. How can a support coordinator assist a participant in need of advocacy without acting outside the parameters of their role? What are the appropriate parameters of the personal advocacy role and the support coordination role?
Conflict of interest
17. In what circumstances is it more or less appropriate for a participant to receive multiple supports from a single provider?
18. Should the IAC recommendation for the NDIA to enforce an “independence requirement between intermediary and other funded supports at the participant level” be adopted?
19. What impacts would stricter conflict of interest requirements have on NDIS participants and the NDIS market?
General
20. What would you identify now as the current critical issues around support coordination?
21. What are the priority actions the NDIA might take to grow an innovative and effective support coordination market in the interests of participants?
