Submission: National Disability Insurance Agency 2023-24 Annual Pricing review Consultation

The National Disability Insurance Agency invited responses to the 2023-24 Annual Pricing Review Provider Consultation Paper.

The AHPA Annual Pricing Review submission repeats themes that AHPA and other entities representing therapy support providers have for some years now conveyed to the NDIA. AHPA also stresses that if therapy support provider views are not heeded in this pricing round, it is only a matter of time before this essential aspect of the NDIS collapses.

Referring to Deloitte Access Economics research prepared for Ability First Australia that develops an allied health cost model for NDIS-funded services (published in 2021), AHPA emphasise’s how costs exceed the price caps imposed by NDIA for the five largest professions involved in therapy support. The submission argues that many small and medium sized allied health businesses are actually subsidising the provision of services to NDIS clients.

AHPA highlights the need to address the stark fact of considerable underutilisation of therapy supports – the proportion of supports actually paid for compared to the amount approved. Therapy utilisation is significantly worse than utilisation in the Scheme as a whole. In the NT and Tasmania participants are spending less than half of the funding that has been allocated for therapy services, while the utilisation is less than 60% in most states and territories. While Australia cannot lawfully permit denying reasonable and necessary supports to participants, AHA warns the NDIA this is in effect what is happening.

AHPA makes five recommendations to the NDIA review, including:

  • increases to the price limits for therapy supports to reflect the cost increases since 2019 and to maintain their real value in future years;
  • our strong view that the Agency and the NDIS Commission should take the lead in collecting data and publishing analyses relating to therapy support workforce mapping and gap analysis, to ensure good workforce planning. AHPA and its members are not funded to conduct this research, and it is the product of considerable work of our members surveying their member professionals about their workforce practices and issues that makes any evidence available at all; and
  • AHPA also endorses OTA’s recommendation for consultation with the allied health sector and the development of a specific bottom-up Cost Model to estimate the true cost of allied health service provision under the NDIS.

Download the submission for further detail.