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We emailed Martin Hoffman this morning to request that the NDIA urgently reconsider the 2 week window for SIL price controls submissions – 4 to 6 weeks is more realistic.
You may recall on Monday we published an article alerting you that the Submissions to the Review of Supported Independent Living (SIL) Price Controls Issues Paper is now open, with a 13th September deadline. We have now had a chance to unpack the scope of responses required and quite frankly, a two week timeframe is nothing short of outrageous.
Is this Scheme sustainability at any / all costs?
Background
The announcement of submissions opening was made on the 31st August.
The Review of Supported Independent Living Price Controls (August 2020) document that frames the reference areas of the review contains no fewer than 40 questions (many with multiple questions within questions). Many of these questions related to the Disability Support Worker Cost Model and seek for respondents to provide evidence regarding any departures they may have from the cost models assumptions.
A sample of some questions include:
1) Do training requirements – and associated costs – for workers differ between SIL services and non-SIL services? If there is a difference, what are the key drivers of this difference? What aspects of delivering SIL services require more (or less) staff training? How large is this difference?
2) What is the average vacancy rate across your properties?
3) Is the vacancy rate of a property influenced by factors such as the complexity of participants in each property, the rurality of the property, and the number of rooms in the property?
4) Some costs associated with vacancies can be considered to be “fixed” – for example, an inactive sleepover for a three bedroom house has the same cost whether there are two or three participants in the house. Other costs can be considered to be more “variable” – for example, the vacancy costs of a three bedroom house with three residents each receiving 1:1 supports can, in general, be managed through change in rostering. What proposition of vacancy costs are fixed or variable in your organisation?
5) What impact does participant complexity have on the costs of delivering supports in the SIL environment?
6) What approach is used to optimise the allocation of participants with different support needs across your properties?
This is just 6 examples from the 40 questions.
Why is 2 weeks unreasonable?
Right now, SIL providers are frantically working on spreadsheets and cost models – no, not to formulate the evidence based responses to the review – most are doing this to try and determine if their services are even viable right now. This is a direct result to the recent and quite significant changes to a lot of the SIL market. Such changes include:
- Counter offers to submissions offering less funding on a take-it or leave-it basis
- Introduction of price limits
- Roll over of SIL funding despite changes to people’s needs
- Massive changes to the back office for claiming irregular supports and others
It is fair to say that the pace of change has caught most providers off guard. Then, on top of all this, just about the time when providers are starting to realise the full impact of changes, this submission is open for just 2 weeks. Even in times when SIL is stable, 2 weeks would be a stretch. In the current environment it feels just wrong.
Future of SIL
SIL is on the nose. There is no getting away from that fact. And most stinky of all, for the NDIS, is the near $9B of committed funding for SIL. However, it is also vitally important when trying to solve this problem, that the NDIS realise that 24,119 people around Australia rely on SIL and a lot of these people have complex support needs. Many of whom do not fit conveniently into the disability support worker cost model to adequately and safely meet their most basic human rights and support needs.
Are there better models of living than SIL? Sure there are. But to take the journey to get to these models, we must respect the current environment. We must give providers a reasonable opportunity to answer the questions and provide the evidence to inform an intelligent, considered and appropriate review of SIL price controls as they stand today.
I am the first to agree that there are some providers still hanging onto the “old ways” and are increasingly frustrated trying to squeeze a block funded model into SIL – but in my experience these are the minority. Most providers I come across at least, are providing “real” SIL and are doing their best to support people to build their capacity and live more independently. Last time I checked this was fairly important in an insurance scheme.
