NDIA Releases Detail on Changes to Planning

On Thursday, June 3, the NDIA released a technical paper on Personalised Budgets, the Agency’s new term for NDIS plans, which have a whole new planning process behind them. The term has been dropped into NDIA communications since late last year, but there has been a notable lack of information about what Personalised Budgets are and how they might inform a plan. 

 I would love to tell you that this knowledge gap has been remedied, but that is only partly true. The technical paper does provide some new information but, overall, we’re still left with more questions than answers.

A great deal of the paper is dedicated to justifying this new approach to planning, but we’ll spare you a summary of all that, out of respect for you and your mental wellbeing. Instead, let’s jump into the information you’re actually here for: what the hell is happening and how it will work. 

What is a personalised budget?

A Personalised Budget is basically what we call a plan in the current process. However, the way Personalised Budgets are developed differs from the current planning process (more on how the sausage gets made later). 

The Personalised Budgets model will work out a draft plan that will usually become a person’s final plan unless what the NDIA calls “exceptions” apply. Exceptions are circumstances that the Personalised Budgets process can’t reliably account for. The exceptions identified to date are: 

• High cost assistive technology (AT), home modifications and vehicle modifications. 

• Student transport. 

• Personal care in schools. 

• Complex life transitions (such as a change in informal supports). 

• Participants in Residential Aged Care. 

• Participants receiving funding from compensation schemes. 

• Extremely complex support needs.  

As you can see, most of these exceptions are supports that sit at the intersection between two funding bodies, where complex billing arrangements are in place. The most interesting exception is the one that applies to people with extremely complex support needs. In these circumstances, the paper says that the Personalised Budget will be closely reviewed by an experienced planner. No definition of “complex support needs” is provided, but maybe it will be people currently supported by the complex support needs pathways. We also don’t know whether participants will be aware if a planner has looked over their plan. 

What informs the personalised budget?

Personalised Budgets are developed with data collected from, you guessed it, Independent Assessments (IAs) – the high-stakes, deeply personal conversations with strangers that everyone is just so pumped about. The participant and their support team do not have an opportunity to contribute to Personalised Budgets, other than during the IA itself. 

But here’s where things get interesting. PBs will be developed based on two pieces of information collected during IAs: 

• The functional capacity assessment

• The impact of environmental and personal factors

The second point is curious. Basically, the results of the functional assessment will determine the “profile” of the participant. Profiles are sometimes interchangeably called reference groups or personas. There are about 400 profiles, each with a dollar amount attached. The process then recognises “that each participant is an individual and may not match perfectly to one individual profile.” So, this first plan budget is then adjusted based on the participant’s response to environmental and personal questions. Factors that might be taken into account include: 

• Where the participant lives 

• The age of the participant

• Informal supports

 This process is best explained in the diagram below: 

It is a relief to see that part of the process considers personal circumstances and that the functional assessment won’t be the be-all and end-all of a plan. However, there are still a lot of unanswered questions. Most importantly, we don’t know how big a role environmental and personal factors will play in plan development or whether they only apply in certain circumstances. Personally, I think the success of the model is determined by how big an influence these factors can have. 

But it is possible that only a predefined set of specific circumstances will be taken into consideration, such as when a child is graduating school. Moreover, the fact that experienced planners seem to become involved only when a person has complex support needs suggests that this second step is also developed by a computer algorithm. For example, an extra loading is automatically applied if the Independent Assessor tags the words “remote” or “very remote.” Or funding is decreased if the assessor says informal supports provide a high level of personal support. 

To be clear, there is no evidence that this second step will be quite so automated. However, there also isn’t any evidence that an actual human will be involved in any step of the budget development (except the Independent Assessor, of course). The example profiles at the end of the document only include personal context information about the person’s living situation/supports and AT needs. Tacking on personal circumstances with a couple of questions at the end of the process does seem to run counter to the social model of disability. 

For a “technical paper,” technicalities are notably lacking. For example, will personal factors being considered in a “tick-a-box” form with only a predetermined set of environmental and personal factors considered relevant by the Agency, or will it be more free flowing and a chance for participants to explain their unique circumstances? Will environmental and personal factors account for 20% or 80% of the overall budget? These are some of the many questions we just don’t have answers for.  

How is the NDIA developing the profiles/personas/reference groups?

The multi-billion-dollar question! The paper says the NDIA is developing the profiles using data from the IA pilots and “expert planners and allied health professionals.” 

This process is still being developed, but it seems these planners and allied health professionals have come up with the 400 profiles that somehow manage to capture all NDIS participants. They have then developed a draft budget for each profile. 

This is where the data from the pilots come into play. They look at the profile budgets they have developed and compare them to the results of the pilot IAs and participants’ existing plan budget utilisation rates. Adjustments have been made for “known biases,” including:

• Budget is increased or decreased depending on the socioeconomic status of the area. This is because, on average, there is a difference in plan size in different socioeconomic areas (side note: interestingly, for adults it is the middle-income areas which have the highest plans). But making such an adjustment based on nationwide averages seems like a risky strategy, as individual regions will have their own variations. 

• Utilisation information will be adjusted for known sources of underutilisation, such as first plans. 

All this information goes into informing the budget for each profile. The paper also says that separate models will be developed for the following groups of participants: 

• Aged 0–6

• Aged 7–17

• Aged 18+ and living in Supported Independent Living (SIL) 

• Aged 18+ and not living in SIL 

Where do goals come into this?

The short answer is that goals will no longer have an impact on what budget a person is allocated, only on how that budget is spent. 

However, the paper does seem to make a bit of a distinction between “goals” and “milestones.” While the NDIS is moving away from funding participants to reach their individual goals, it will adjust budgets for certain life milestones like moving out of home, finishing school, or getting a job. 

When can we expect personalised budgets to come into effect?

Not for a while! The paper says quite clearly that they can’t implement this new planning process until the new NDIS Act is passed through parliament, and who knows when that might be. Earlier this week, Senator Linda Reynolds said she did not believe IAs in their current form had a path through the Senate. 

How are PBS different from Typical Support Packages (TSPs)?

Very good question! TSPs are example budgets that tell the planner what funding the NDIA would expect a person to have based on disability, level of function, age, and so on. Planners adjust TSPs based on information gathered during the planning meeting, though they aren’t encouraged to develop plans higher than the TSP too often. According to the paper, the TSP model has a few limitations: 

• TSPs are underpinned by inconsistent, poor-quality data, including participant-sourced functional assessments and guided questions in planning meetings. 

• On average, functional capacity determined through assessments has decreased over time, leading to higher TSPs. 

• The number of participants recorded as having no informal supports at home increased after TSPs were introduced, leading to higher TSPs. 

The last two seem classic cases of correlation not implying causation. It’s hard to know how TSPs could have erased informal supports. There is also the suggestion that the TSP model is too fundamentally broken to be improved.  

At a guess, I would say the difference between TSPs and PBs will be the level of human involvement in the process. Under the TSP system, planners still have significant influence over the final plan budget. We can only assume there will be less oversight once PBs are implemented. 

That’s it for PBs, at least for the time being! Maybe we will learn more in the future, or maybe we won’t. You can read the full paper here: https://www.ndis.gov.au/about-us/improving-ndis/plan-flexibility-and-budget-planning.