Group Supports and the new Price Guide – a massive oversight or a serious threat?

A provisional version of the 2020-21 Price Guide was released last week and while we’re still waiting on the final price limits to be announced, it already describes a series of new rules that would fundamentally change the way that group services claim for their supports, including:

The number of line items in Assistance with Social and Community Participation has gone from 225 to 87.
“Centre based” and “community based” line items have been removed and replaced by line items that do not name the support location. The idea now is that providers delivering a support in a centre will make a claim with two components: the support time (e.g. Group Activities - Standard - Sunday) and the newly introduced “Centre Capital Cost” - currently sitting at $2.31 per hour in non-remote areas with the final price to be confirmed.
Providers may now also claim for the non-labour costs of provider travel
Line items that refer to specific ratios are gone. The NDIA now expect providers to do their own math and claim the relevant fraction of one price limit. Based on the Standard rate (without TTP), this means community group supports revenue could be reduced by 11% - 32%.

And it’s that last change that has us most concerned. But before we get into the detail, a little context:

In last year’s initial Price Guide release, the NDIA greatly reduced the price of group services with no explanation. A week later, after much lobbying from the sector, they were increased, again with no public explanation. DSC’s understanding of this back and forth was that the initial (decreased) price allowed group services to claim additional hours of non-F2F time so the non-F2F time that had been built into the initial price limit was removed. When the price limit was then increased, the NDIA removed the option for providers to bill for additional non-F2F time.

It is entirely possible that what is playing out in the 2020-21 Price Guide is just another case of the NDIA poorly communicating how they expect providers to make up for the price reductions that appear to have been made. But if that is not the case, the future of groups supports as we know it seriously hangs in the balance.

Revenue comparison

Our calculations below demonstrate just how much providers stand to lose from the merging of ratio line items. While the actual prices remain to be finalised, the fact that providers will lose out big time at higher ratio levels remains clear.

Considering a lot of providers DSC works with have indicated day programs are a loss leader, it is difficult to see how providers will be able to remain open with such a significant loss on top of the recent closure of these types of support as a result of COVID-19.

Some of the losses above will be made up by claiming non face-to-face time (around 5 minutes per person for every hour of direct support, if you want to be specific). This will require all providers to outline the non-F2F activities for each individual participant, get the person’s sign-off on this list and then accurately log and claim all instances of non-F2F for each person. On the other hand, many providers may argue that a large portion of the increased costs they face to deliver supports at higher ratios do not meet the non-F2F claiming criteria.

While we welcome any change that puts more power back in the hands of participants, we have to wonder if the value of groups has been lost in this simplified approach. Group services are all about the outcome the program aims to achieve for the group; social connection, specific and general health and learning outcomes or skill development. As a result, the development of the program towards meeting the stated group outcome is where investment is required. With every instance of development work now needing to be attributed to an individual, the NDIA have stripped out the funding that allowed providers to invest time and resources into program development, establishing the learning pathway and activities and connecting to community activities and events. These activities are completed before the commencement of any group program and can arguably only be partially recouped by claiming non-F2F hours.

Some personal outcomes are better achieved in a group, with like-minded people who want to learn together. Whatever you think of day programs and where group services have come from, there are providers out there delivering life-changing, goal focused, outcome-achieving supports in group settings. If this price change goes through, we could see innovation in group settings disappear. And that's not good for choice and control.

Claiming rules for ratios

The NDIA has also included some general rules for claiming that apply to all supports delivered in a group, regardless of support category. In addition to the replacement of ratios for all group programs with the apportioning of time spent, the NDIA has described how providers should claim for multiple staff engaged in the group program. "Provider should only claim for the time of more than one worker against that participant's plan if all those workers were involved in the direct support of the participant at the time claimed".

Many providers are wondering how this rule will impact their rostering and claiming processes and what the administrative cost will be of logging and claiming all interactions through the course of a group support. These questions are yet to be answered by the NDIA.

Programs of Support

We were pretty excited to see the inclusion of Programs of Support until we saw the detail. Providers of group based supports in Assistance with Social, Economic and Community Participation Support Category (yes, this support category has a new name, probably to highlight the inclusion of employment supports into the category), can enter into an agreement with a participant for a "program of support", especially where the program is towards the achievement of a specified outcome.

Apportioning the time spent on the support among the Participants is still relevant to Programs of Support. There are additional conditions that apply:

The program can be no longer than 12 weeks
Participants can exit with up to 2 weeks' notice (note that the otherwise standard short-term cancellation policy is returning to “2 clear business days” from 1 July so this represents a signficant difference)
Must have a service agreement with Participant
Claimed post instance of support - no pre-claims

It’s not entirely clear to us how this differs from alternative forms of support. It appears by bundling together supports, providers are able to promote discrete programs like a term of Autism Swimming Lessons and claim per Program of Supports regardless of attendance and will not be subject to the short notice cancellation rules. If Participants wish to exit the program, they will be required to give 2 weeks-notice. This approach enables providers to better budget for staffing and costs of delivery, however, the price rules still apply and with the current hourly rate may not be viable.

Group supports under capacity building

Unlike their core supports counterparts, group supports delivered under Therapeutic Support, Exercise Physiology & Personal Well-being Activities are unaffected by the move away from ratio-specific line items as the existing prices were already proportional. Providers delivering these group supports will only need to change the support item number and apportion the time spent on support amongst the participants.

Early Childhood supports, on the other hand, will see a reduction in their revenue, as demonstrated in the table below:

As you’ve probably picked up by now, there are a lot of lingering questions around this year’s Price Guide release. We can only hope that some of the inconsistencies and concerns we’ve outlined here are miscommunications or oversights. We will certainly continue keeping an eye out as revisions are released and will continue writing it up as we do.