Programs of Support Maze

When the Programs of Support (POS) service and billing model was launched in July 2020 (can you believe that was 21 months ago?!?), we were all cautiously optimistic that the new structure would give more security to participants, providers, and workers during an extremely uncertain time. The launch of POS also came with a commitment from the NDIA to publish further guidance about the model for providers and participants and to conduct an evaluation to assess its impact and effectiveness.

Almost two years on, we’re still waiting for that further guidance – which probably means the evaluation is a long way off! In the meantime, participants and providers have been left to muddle through how the POS service works, how it should be billed, and who it might best support. But muddle no longer! We’ve answered some of your most common questions about POS.

Question 1: Is it optional?

There’s been some confusion across the sector about whether it is mandatory to use the POS model. The advice (to date) from the NDIA is that the POS model is optional. A provider and a participant can agree to use a POS model, agree not to use it all, or agree to use the POS model for some services and not others.

Question 2: Is it only for groups?

The NDIA says that only group services can be billed under a POS model. But several months after initial launch, they announced an exception for Early Childhood Intervention services delivered under registration group 0118. These services can deliver and bill for both group supports and related one-to-one supports under a single POS. But every other POS service must be a group support.

However, one-to-one supports can still be delivered in group settings and then billed separately. For example, a person might come to a group run under a POS model and require an hour of one-on-one support in the middle of the day for personal care. In that case, the advice from the NDIA is to bill the two supports separately. The same provider can deliver both services, but from a billing perspective they are independent supports – one part of the invoice for the POS group supports, and other for the one-to-one supports in the middle of the day. This also means that the benefits of the POS model can’t be accessed for the one-to-one supports delivered during the program.

Question 3: Does POS have to be billed with the new apportioned pricing model?

Another point of confusion is whether a POS model must be billed using the new apportioned pricing model, or whether providers can use the transitional pricing model based on ratios. The answer is that the POS model is available to group services providers using either transitional pricing OR apportioned pricing.

Question 4: How long can POS services run for?

Another golden rule of POS is that a program can’t run for more than 12 weeks. That said, 12 weeks is only the maximum (I know of providers offering a POS over a long weekend). If your group program runs longer than 12 weeks and you want to use a POS model, you’ll need to find a way of breaking that program down into smaller chunks. Some providers run group services 52 weeks a year, so the first task is to assess whether it’s practical to break down the full year into blocks of no more than 12 weeks. That will work for some but not for others.

Question 5: Can POS services be billed before delivery?

In the early days, one of the most common misunderstandings about POS was that it could be billed in advance, as if it were Block Funding 2.0. This is not the aim of POS, and the NDIA has been clear that POS, like almost every other NDIS service, must be billed after a service is delivered. However, that does not mean a provider has to deliver all the sessions in a given POS before billing – that is, if your POS is 12 weeks, you don’t have to wait until week 13 to bill. It’s fine to bill on your usual invoice cycle. POS services also don’t use any special line items or bill from any ringfenced part of a person’s NDIS Plan. This means a POS is competing for funds in a person’s Plan, just like any other service.

Question 6: What are the benefits of POS?

Most of the time, the biggest attraction of the POS model for providers is assured billing. If a person signs up for a POS, the provider is able to bill for every session in that POS regardless of whether that person attends all sessions. Of course, the fact that the provider can bill for unattended sessions doesn’t mean that they must do so. Organisations should always apply their own discretion, both when delivering supports in a POS model and more generally.

To access this benefit, everyone has to do a bit more work. Every POS requires a Program of Support Agreement that outlines the length of the POS, the Exit Rules (the notice period a person needs to give to leave exit the POS – the maximum is two weeks), and the Intended Outcomes of the POS. This doesn’t have to be lengthy – we’ve seen POS Agreements that are less than a single page. A new POS Agreement is required for each program.

The POS model is not a fit for every service or every participant – and that’s okay. But when done well, the POS can genuinely benefit all parties.