SIL Submissions Deadline

The last eight months have been bizarre on all accounts. You can be forgiven for not being entirely up to date with the rapid succession of changes for Supported Independent Living (SIL) providers. To start, let’s do a bit of a recap ... 

Around March this year, SIL providers started to receive welcome messages that the Agency was planning to respond to delays in processing SIL quotes. But, when this assistance came, it was in the form of a ‘counter-offer’ process. For those that aren’t aware, this new process involved the provider creating their SIL quote with supporting evidence, and the Agency coming back with an often much lower counter-offer. In hindsight, this was probably a preview of the price controls that were about to be released in July.

In May 2020, the Joint Standing Committee (JSC) tabled the report from the inquiry into SIL. The report listed many recommendations for improving the way SIL was playing out in the NDIS. In August, the Government responded. 

Meanwhile, in July, the release of the 20–21 Price Guide and the new SIL Provider Pack heralded significant disruptive changes. The Joint Standing Committee report was cited as a key driver of many of the changes. Higher participant engagement and capped prices were designed to create ‘efficiencies’ for providers engaged in the quoting process. Since the original release, the Provider Pack has undergone several iterations which feel like reactive responses to the chaos created.

Last month, the Agency called for feedback on the SIL price controls. The deadline for this feedback was felt unrealistic by many, given the circumstances. It has since been extended to 25th October.

Now we move into October and the issue on the table is the call for feedback on a new paper titled ‘Improving outcomes for participants who require Supported Independent Living (SIL)’. Let’s jump into that, shall we?

Improving SIL outcomes paper

This new paper reports several emerging issues with the performance of SIL:

• SIL funding is not always allocated fairly or equitably
• Participants do not have adequate choice and control
• The SIL process is administratively complex
• The rapid escalation in SIL costs is not in the long-term interest of participants or NDIS sustainability

I think serious consideration is needed of how much of these escalating costs is actually due to the provision of additional services that have traditionally been included in SIL supports?

There is a lengthy list of “what’s not in SIL” provided at the end of the SIL Provider Pack that includes items covered in other sections of the NDIS plan. Yet, many providers across the country continue to include many of these items in their SIL quotes (and therefore form part of the ‘escalating costs’). It is no wonder that the SIL budget continues to soar as providers respond in multiple ways.

Without a clear, universally agreed-upon delineation of what SIL is, how can the data accurately reflect the way the budget is being spent?

I think the elephant in the room for all providers right now is the supposed administrative efficiencies being created in the new SIL submission process. Yes, removing the ability to quote and making service bookings on historical data is much quicker. But it runs counter to the need for ‘increased choice and control’ or ‘equitable funding allocation’. SIL providers then have to determine what supports will not be included when a service booking is reduced by tens of thousands of dollars without justification.

We also can’t ignore that those efficiencies have resulted in confusing and complicated manual claiming processes that have seen many providers unable to claim any payments at all … in the middle of a pandemic … with people at home for longer periods than their funding allows …

On a more positive note, a lot of good can come from the guiding principles that are included in the paper. Hopefully, these will be the main driver when considering the future changes. A sustainable Scheme is important, but a rushed, reactive, financially driven design may not be the optimum way to achieve this.

All things considered, it is vitally important that SIL providers gather whatever remaining energy they have to craft a thorough and thoughtful response by October 19th. The provider perspective needs to be included in the design of home and living services under the NDIS to give an understanding of how the changes shape the sector.