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Between price freezes and negotiating conflicts of interest, support coordination and plan management providers have been tackling major issues for a while now. But in the context of a Scheme where a million things are happening all at once, these topics don’t always get the attention they deserve.
The problems that NDIS intermediaries (i.e., support coordinators and plan managers) are facing were well summarised by Disability Intermediaries Australia (DIA) in its evidence before the Disability Royal Commission (DRC) last month.
Let’s take a look at the major issues in the sector as outlined by DIA.
Conflict of Interest
Ahh, intermediaries and conflicts of interest: the thorny topic that the NDIA has barely made a dent in, 10 years into the Scheme.
The DRC heard concerning evidence that some providers are using support coordination as a client capture mechanism. DIA CEO Jess Harper outlined DIA’s Professional Practice Standards requirement that if you are acting as an intermediary, you shouldn’t be able to provide other supports to the same participants. This is due to concerns around coercive control, inherent bias, and the power that support coordinators have over the people they are supporting. In addition, support coordinators need to be able to challenge providers delivering supports – which can be hard when you work at the same organisation.
However, there are some exceptions to this rule, particularly in cases where it is most appropriate for one provider to offer both intermediary and other supports to a person. For example, in some Aboriginal and Torres Strait Islander (ATSI) and culturally and linguistically diverse (CALD) communities, there might be a limited number of providers able to offer culturally safe services. However, in these cases, providers need to be able to demonstrate that they are taking steps to manage any conflicts of interest.
Price Freeze
Many people have lost track of time since the pandemic, but the NDIA seems to have taken this to a whole other level by failing to increase the price limit for support coordination and plan management for three consecutive years.
The NDIA’s Annual Pricing Review said there were two reasons they didn’t raise the price limit for support coordination. First, it believes that most support coordination providers can make “modest returns” under the current price model, despite the fact the NDIA has not released any benchmarking it has done to support this claim. Second, the Pricing Review said it “it would be more appropriate to first clarify the role of Support Coordinators in the NDIS before finalising the pricing arrangements for this support”. Somewhat awkwardly, in November 2021, six months before the review, the NDIA did claim to have clarified the support coordination role in its “Improving Support Coordination for NDIS Participants” paper.
All this has contributed to what DIA has called “a crisis with viability” for intermediaries.
Unpaid work
According to DIA’s Sector Report, 94% of its support coordinator members have provided support outside of the funding in a plan. This raises serious questions about how sustainable it is for support coordinators to continue to do unfunded work. Yet with some people funded for as little as 10–12 hours, it’s hardly surprising that is happening.
Support Coordination vs Advocacy
Where exactly the boundary lies between support coordination and advocacy is the subject of ongoing debate in our sector. Everyone agrees there is a boundary there somewhere, but where exactly?
In its evidence, DIA said that when a participant needs more intense or robust advocacy work, then the support coordinator should support them to engage an advocate. An example might be when the participant is going through a review at the Administrative Appeals Tribunal (AAT). How much advocacy work a Support Coordinator does is often limited by the number of hours in the plan.
Registration
The DRC extensively explored whether providers are choosing to be registered with the Quality and Safeguards Commission. Registration is, of course, compulsory for plan managers. However, support coordination providers have a choice, and the DIA evidence suggests that only about half of its members are electing to register.
Registration is a stressful value proposition for support coordination providers right now, particularly with hourly rates frozen in time. For many providers, the benefits of registration aren’t worth the quite considerable cost. While DIA was not supportive of compulsory registration, it is in favour of a national worker screening program for all support coordinators.
Professional Standards of Practice
The DRC discussed DIA’s Professional Practice Standards for Support Coordination and Plan Management. These came out in March 2022 and were developed in consultation with service providers, people with disability, the NDIA, and the Quality and Safeguards Commission. They are part of an effort to create practice benchmarks to professionalise an increasingly maturing market. DIA is working on an accreditation module.
You can find DIA’s Professional Practice Standards here.
The challenges facing intermediaries are numerous and, unfortunately, not likely to go away any time soon. However, with the bigwigs at the DRC shining light on the issue, hopefully we’ll finally start to see progress.
You can listen to DIA CEO’s Jess Harper’s full evidence to the Royal Commission here.
