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The NDIA last week released the eagerly anticipated update to the Supported Independent Living (SIL) Provider Pack and Operational Guidelines with a surprising announcement:
But hold the celebration – when we look a little closer, it seems that “quotes” are no longer required, “submissions” are. SIL providers still need to gather evidence and complete a Roster of Care (ROC). At the end of this process, they submit an estimate of what it would cost to provide the service to the Agency. This “submission” sounds remarkably similar to the previous process, and suspiciously like a quote.
If this is the case, why make such a big deal about it? The “No Quoting” furphy may be just a case of misdirection to a more significant and concerning issue.
When the Price Guide was released last month, it included major changes to SIL: the introduction of price controls under “standard” and “higher needs” pricing categories. This change was already set to have a significant impact on providers as the price limits attributed to the categories is significantly lower than those that have been used previously.
The new Provider Pack allows for the Participant need level to be separated from the price level. It also defines what would qualify a person for a “Higher Intensity” funding level. And it looks like this classification is much narrower than that what was used previously.
To cost your non-quote at the higher level, the Participant will need to meet one or both of the following.
- There is frequent (at least 1 instance per shift) assistance required to manage challenging behaviours that require intensive positive behaviour support; and/or
- There is continual active support required due to high medical support needs (such as unstable seizure activity or respiratory support)
The guide to the provider pack also stipulates that all Participants will be classified “Standard” as default, and significant evidence will need to be provided to justify an increase. What this means is that most providers have now taken a second hit to their costings. Many providers will now use the rates that were previously utilised for the “lower” category for Participants who have been costed at “Standard” and “Higher” for several years.
Another notable amendment is the transparent capping of the Irregular days allowed per support level group. While this can seem restrictive, it is actually a welcome change. We see a vast difference between the previously required maximum irregular hours across states and even regions varying between 5-30 depending on the planner. This will ensure that arbitrary decisions cannot be made on the whim of the person that is processing your submission. SIL providers will also now be able to clearly evidence the supports that are being provided on top of that which they are being funded for. Even with a change to the way Irregular supports is are claimed, providers have options to request additional funding through core to cover more community-focused holiday periods which can only be a positive change for Participants. Providing funding follows in the core budget.
Several other changes look to be positive at first glance…
The SIL ROC submission template
This document has been historically used for the Provider to give an outline of the Participant, their current support needs and the intended outcomes. The new version provides much more guidance around the type of information that would be helpful to include to facilitate a good outcome. These include
- The template requests specific information on the behaviours of concern and asked for an active, in date Positive Behaviour Support Plan
- Allows Providers to identify and document Participants need for 1:1 or greater support
- Questions the stability of the Participants support needs
- Specifically asks for Community Access or (CP) timeframes
- Requests contact details for the Participant decision maker
- Clarifies the type of overnight support provided in the property
- Allows space for supports to be shared with people not living in the property (neighbouring residents) which opens up service options substantially
The SIL ROC submission tool
From a first glance, the ROC looks similar to the previous version. The major difference is on the overview page. The following apparent changes have occurred
- More details are required regarding the SIL provider
- The participant needs level is separated from the participant price level
- Hourly rates are pre-populated
- There is provision for updated rates nominated by the Provider (however these can only be lower than the current price limits)
- Irregular supports are still included
The declaration of consultation
The declaration now asks providers to acknowledge that Participants have been provided with a copy of the RoC. While there are some privacy challenges concerned with sharing this document that covers off the funding of others residing in the house, anything that can increase consultation and build relationships is welcome.
What is SIL and what isn’t SIL
The final notable inclusion is information regarding what is part of the SIL service and what is not. Last week, we released an article that started to unpack SIL from a financial viability perspective and the apparent need to understand your costings. The Agency has helped give more guiding information around this topic. This will assist providers to be able to have more clear and transparent conversations about the service they are providing and those things that are add-ons that can potentially be funded via other parts of the plan.
This is the first in a series of Articles that will follow the implications of the new SIL Provider Pack. You can also join the conversation about the implications by signing up to the SIL workshop series
