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Almost every day program provider we talk to is confused and stressed about Non-Face-to-Face supports, which can now be billed by providers delivering Group and Centre Based Activities. This change was announced in the July Price Guide update last year, and it’s got providers scrambling. The majority of providers delivering Group and Centre Based Activities have never thought about what Non-Face-to-Face supports they deliver, how they are individualised, or the amount of time they spend delivering them. These activities have always just been par for the course. This change will require a rethink of the scale and scope of services delivered.
So, let’s do a refresher on the changes, their implications, and the answers to the questions we are most often asked.
WHERE DID THIS CHANGE COME FROM?
In July 2020, the NDIS dropped a bombshell. Well, it was multiple bombshells to be precise, but the most significant change in the Price Guide for many providers was that group services can now bill Non-Face-to-Face services. This mostly affects group services billed against Core where providers were using the ratioed pricing model (one worker: multiple participants). Until July 2020, these services couldn’t bill Non-Face-to-Face supports as separate services.
WHAT EXACTLY HAS CHANGED?
Non-Face-to-Face no longer forms part of the ratioed price limit that providers just have to accept. If you deliver two hours of Non-Face-to-Face supports to a participant accessing your day program (maybe a worker contributes to an OT assessment, you tailor the day program to someone’s specific requirements and aims, or you spend some time liaising with the person’s Support Coordinator about an update to goals), then you can bill that.
There’s a caveat, though, and it’s an important one: Non-Face-to-Face supports can only be billed if you’re using the new apportioned pricing model. Ratioed pricing still exists in the Price Guide until 30 June 2021, and the Agency says there’s already an element of Non-Face-to-Face supports built into that. So, if you’re using the ratios, you can’t bill Non-Face-to-Face until you move to the new model.
WHY DID THE NDIA MAKE THIS CHANGE?
We should say at the outset that the ratio model wasn’t perfect. It didn’t give much flexibility for providers to offer responsive, agile services. Further, it often masked the true scale and scope of the work that group service providers delivered. We don’t know for sure why this change was made now, but we do know that it was on their radar for several years, in response to peak and market pressures. It also makes the system more transparent for participants, who can now see exactly what Non-Face-to-Face supports they are paying for.
I’M NOT SURE IF YOU’VE NOTICED BUT AS A PROVIDER, I’M ALREADY PRETTY BUSY. IS THE NDIA GOING COMMUNICATE THIS WITH PARTICIPANTS SO EXPLAINING IT DOESN’T BECOME MY RESPONSIBILITY?
Tell him he’s dreamin’! The NDIA has not released any guidance for participants and families, nor has it shown signs of releasing any. The sole resource for this change is the Price Guide, so our inference is that the Agency expects providers to lead this conversation with participants, taking on the roles of educator, salesperson, and service provider all at once.
I HAVE NO IDEA HOW THIS WILL WORK FOR MY ORGANISATION. WHO ALREADY DOES NON-FACE-TO-FACE THAT I CAN TAKE FOR A COFFEE AND PICK THEIR BRAINS?
Non-Face-to-Face is not new to the NDIS market; it’s just new to group services billed from Core. Capacity Building providers (including Support Coordinators) have been doing it for a while, and it’s fully ingrained in some service types like therapy supports and Early Childhood Intervention services. So, these are the local networks to start mining! If you are a larger provider, there may be people in your organisation already billing for Non-Face-to-Face for other services. But buy them coffee if you’re going to grill them.
HOW WILL THIS LOOK ON OUR INVOICES AND CLAIMS TO THE PORTAL?
There are two main implications for invoicing and claiming. The first is that Non-Face-to-Face has to be listed separately from any other supports (separate from Face-to-Face supports, travel, separate or Activity Based Transport, etc). So, your invoices are likely to be much longer now: good news for printer paper suppliers, bad news for trees.
The second important thing is that Non-Face-to-Face is a claim type, not a Support Item. This means that in the Portal it’s in the dropdown menu alongside Direct service, Cancellation Charges, and Provider Travel. So, all Non-Face-to-Face supports have to be linked to a Face-to-Face support but listed as a separate line on an invoice or claim.
WHAT CAN AND CAN’T PROVIDERS BILL FOR NON-FACE-TO-FACE SUPPORTS?
The Agency has given very little guidance on what can and can’t be billed for Non-Face-to-Face supports. In the Price Guide, there are eight examples (on page 17) of what cannot be claimed:
- pre-engagement visits
- developing and agreeing Service Agreements
- entering or amending participant details into system
- making participant service time changes
- staff / participant travel monitoring and adjustment
- ongoing NDIS plan monitoring
- completing a quoting tool
- making service bookings and payment claims
Outside of these clear no-go activities, there’s no further guidance. The Agency expects providers and participants to negotiate over what will and won’t be billed as Non-Face-to-Face supports, which is a position many day program providers have never had to navigate before.
WE NEED TO WORK OUT WHAT NON-FACE-TO-FACE SUPPORTS WILL LOOK LIKE FOR US, BUT HOW SHOULDN’T IT LOOK?
It’s vital to remember that Non-Face-to-Face is not a clearing house for every business process or admin task that costs you money. Billing any unjustified Non-Face-to-Face is going to turn participants and families off pretty quickly (and word travels fast in the NDIS market).
As with other NDIS services, the Non-Face-to-Face supports you deliver need to be individualised and connected to goals. The NDIA’s old costing model included a 12% additional loading for every ratioed hour of Core supports delivered to account for some Non-Face-to-Face support. But that doesn’t mean that providers should start looking for anything they can bill to reach that 12%.
OK, YOU’VE CONVINCED ME. THIS IS A GREAT CHANGE, ISN’T IT?
In a way, yes. And in another way, no. It does mean providers can get paid for the Non-Face-to-Face supports they’ve probably been delivering all along. However, as the NDIA has opened up Non-Face-to-Face supports to group providers, they have also made significant cuts to the pricing for Face-to-Face group supports. Most providers will have no choice but to start billing Non-Face-to-Face supports to make up the difference between the old and new pricing.
We can’t sugar-coat it and pretend there’s not a lot of work for providers. It’s gonna be Changeville for a while (but that’s nothing new, right?). And like anything in life, any opportunity comes with some trade-offs.
WHAT CAN PROVIDERS DO TO GET READY?
There are a number of things providers can do to prepare for billing Non-Face-to-Face supports:
- Start tracking all the activities you deliver right now, down to the tiniest details. From there you can start filtering what can be billed for Non-Face-to-Face supports, what you feel comfortable negotiating with participants, and what straight-up isn’t eligible.
- Accept that this is probably going to change the dynamics of your relationships with participants and families, at least for the coming months. At some point this will become the new normal (how many times did we hear that in 2020?!), but for now things you’ve previously done and included in your service will have to be justified, negotiated, agreed, and recorded in a Service Agreement or Schedule of Supports. We think the best way to address this is head-on. That doesn’t mean forwarding families the Price Guide and asking them to come back to you with questions but communicating effectively with your audience.
- Check how your systems – including your Customer Relationship Management, Client Management system, or rostering system – are set up to bill for Non-Face-to-Face supports. Some software vendors are already all over this; others, not so much. The last thing you want is to throw a transition to a new IT system in amongst all this change, so ask your current IT team some pointed questions ASAP.
- It’s impossible to talk to too many people about this change: workers, program managers, participants, Support Coordinators, family members, finance teams, organisations you’re friendly with. The more information you have from the more sources, the better informed and grounded any decision is going to be.
- Check in with your workforce on the change – what do they understand about it? What are they excited about? What are they nervous about? What are their preferences? The success or failure of this change is (like so many in the NDIS market) is going to come down to the frontline workforce making it work.
- Keep an eye out for our upcoming workshops and webinars on your group services transition. We go into Non-Face-to-Face in more detail in our Rebuilding Day Programs workshop, along with other elements of the pricing model change.
Nobody is saying this is going to be easy, but the change is here to stay. So the more informed you are as a provider, the better the transition is going to be for everyone.
