Could planning meetings become a thing of the past?

Today the NDIA has dropped no less than 3 Discussion Papers for community feedback. I know what you are thinking- “oh great another discussion paper.” That was me at 10am. But trust me when I tell you that these ones are Big with a capital b. Until today, I had not fully understood the meaning and range behind this emoji 🤯

The Papers cover the following topics:

· access and eligibility policy for independent assessments;

· planning policy for personalised budgets and plan flexibility;

· supporting young children and their families early, to reach their full potential.

To do justice to each of the Papers, we will be covering each of them separately over the coming days. Today we will be focusing on personalised budgets and plan flexibility.

Some of the changes proposed are pretty momentous, but it is really important to note that they are not finalised policy yet. If any of these changes upset you, don’t panic. As the English say, Keep Calm and Submit Your Feedback. You can find more information on how to do that at the end of this article.

GOODBYE PLANNING AS WE KNOW IT

From what we can tell, the NDIA seems to be signalling some pretty dramatic changes to the planning process. We have known for a while now that they plan to start implementing Independent Assessments (IAs), but the link between them and plan budgets has not been clearly defined. But now it seems like the NDIA’s plan is to use IAs to develop a draft plan budget without conducting a planning meeting, as you can see in the diagram below.

Draft plan budgets are not finalised. However, the Paper lists only two circumstances where drafts can be changed. These are when:

a participant has extensive and/or complex support needs (for example where a participant has substantial behavioural support needs, a plan is expected to be of extreme high value, or a participant requires increased temporary support in response to an emergency)
there are additional high-cost supports required that are not accounted for in the independent assessment. These supports include Specialist Disability Accommodation, high-cost or complex assistive technology and home modifications.

Accordingly, with plan budgets largely determined by IAs, planning “conversations”, as they are now referred to, “will no longer need to focus on the negotiation and agreement of each individual support.” Instead they will primarily be focused on plan implementation.

Like I said: 🤯

A NEW WAY TO CALCULATE BUDGETS

Right at the beginning of the report, the NDIA state they want to move away from “building a plan based on funding for each individual item or support” to simply “total reasonable and necessary level of funding for each participant.” How they can work out a total budget without some idea of the individual supports required is frankly beyond me.

The plan seems to be for IAs to assess a person’s functional capacity, taking into account environmental factors, informal supports and individual circumstances. The results of the IA determine the plan budget so that participants with similar levels of functioning and in similar contexts will get roughly the same plan.

PLAN FLEXIBILITY

The good news is that plan budgets are likely to (finally) become flexible. Budgets will have 2 types of supports:

Flexible budgets- which can be used for any disability specific support eligible for NDIS funding.
Fixed budgets- which include funds for identified supports. This seems to be similar to what used to be called ‘stated’ supports in the old system.

And the 15 support categories? Well, under the NDIA’s proposed approach they will be a thing of the past.

RELEASE THE FUNDS

Plan budgets will now be up to 5 years long. However, funds will only be released to the participant in intervals- either monthly or quarterly. Funding for supports like Assistive Technology will be exempt. Participants can request additional funds in an interval if, for example, they want to make a bulk purchase. Unspent funds will roll over to the next month or quarter.

REVIEWABLE DECISIONS

The reviews process for planning decisions has not changed. But (and it’s a big BUT), IAs themselves will not be reviewable decisions. This is because they are technically not ‘decisions’ even though they seem to be the main piece of evidence informing planning decision-making.

Participants will not be able to request a new IA if they disagree with the results of the assessment. They will only be able to request a new assessment if there has been a change in circumstances or “the assessment was not consistent with the independent assessment framework.”

HOW OFTEN WILL PARTICIPANTS NEED TO DO AN IA?

The NDIA is proposing that participants participate in an IA at least once every 5 years. The suggested minimum time between assessments is 3 months.

PLAN VARIATIONS

Plan variations can occur without an IA or plan review. However, variations can only make specific changes, including:

Adding funds for supports that don’t require an IA- like assistive technology and home modifications.
Moving funds from flexible to fixed or fixed to flexible
Changing plan management type
Changing intervals for releasing funding
Changing frequency of check-ins
Making changes that do not impact the total plan budget
Updating goals
Fixing errors

If the total plan budget needs changing, then an IA is required.

GOALS?

You might be wondering where goals fit into this new process. As you can see from the diagram above, they do not factor into the draft budget. But participants are still supposed to use their budgets to work towards defined goals.

EXCEPTIONS

There are limited circumstances where the participant will not be required to undertake an IA. These are:

a) Risk and safety: where the process is likely to do more harm than benefit to the individual, and may pose a safety risk to the individual or the assessor (this may include where paranoia is present and severe, there are severe behaviours of concern, or specific trauma related concerns which can’t be alleviated).

b) Assessment is inaccessible or invalid: where there may be concerns about the process producing valid information and other sources and/or forms of information are better suited (e.g. a support person can’t be identified to complete relevant components of the independent assessment).

YOUR FEEDBACK IS REQUESTED

Submissions are due by 10am on the 23rd February 2021. So you have time to think about what you want to say. There are 12 discussion questions at the end of the Paper:

How should a participant’s plan be set out so it’s easier to understand? How can we make it easy for participants to understand how their funding can be spent?
How can we support participants to prepare for a planning meeting? What might be needed to support participant decision-making?
Which supports should always be in the fixed budget? What principles should apply in determining when supports should be included in the fixed budget?
How can we assure participants that their plan budgets are at the right level? (e.g. panels of the Independent Advisory Council that meet every six-months to review learnings and suggest improvements)
What new tools and resources should we provide to support people using their plan and new plan flexibilities?
What do we need to consider for children aged 7 and above in the new planning process?
What ideas do you have for how people can use their plan more innovatively?
How best to handle the timing of the release of funds into plans and rollover of un-used funds?
How should check-ins be undertaken? Under what circumstances is a check-in needed? Who should be involved in a check-in?
How often should we check-in with participants in different circumstances?
How can the NDIS ensure positive relationships between participants and planners?
How can we best support participants to transition to this new planning model?

You will notice there are no questions about IAs or how they impact planning decisions. Innocent mistakes we are sure… But they do also say that they “welcome any feedback on the policy as it is outlined in this paper.” So by all means don’t limit yourself!

Click here for more information about making a submission.

Click here to read the full Discussion Paper.