Published 17 August 2023
AHPA recently responded to a Consultation Paper from the NDIS Review, on the role of pricing and payment approaches in improving participant outcomes and NDIS sustainability.
Our members agree that NDIS pricing arrangements need improvement, but we disagree with some of the Consultation Paper’s proposed changes and accompanying rationale. AHPA has been saying for some time that it is inappropriate to produce ‘solutions’ that rely on a pure market model to address the imperfect market that is the NDIS. We also see the role of allied health in providing therapy supports and other services under the NDIS as carrying its own specific challenges that need to be considered – one size does not fit all.
Over the last few months therapy support providers have been blamed in some public statements for ‘price gouging’. Unfortunately this scapegoating without substantive evidence is repeated in the Consultation Paper. The assertion that allied health providers charge participants too much is often accompanied by comparison to ostensibly lower private sector and Medicare prices, and fees under State and Territory schemes. However, as our members have repeatedly told NDIS Price Reviews, this ‘compares apples with oranges.’
The price gouging myth seems to be at least part of the basis for the Paper’s market theory -derived proposal that providers should be given incentives to provide high quality services to participants. The paper claims that at present there are ‘perverse incentives’ for providers to maximise the volume and types of supports they deliver, because this maximises the total payment they receive.
This is not how providers of allied health supports operate as clinical health professionals, and one wonders how this assertion would be received by GPs. In reality, NDIS data on underutilisation and actualised payments is that utilisation rates of therapy supports are much lower than those of NDIS services as a whole. This means that far from participants being ‘overserviced’ by allied health, they are often not receiving the therapy supports that they need and have been approved to receive.
We also pointed out to the Review the considerable risk posed to therapy support service delivery within the Scheme by what have effectively been reductions in the current price for therapy supports, given the failure to index therapy support prices for four years running (and which is not the case for other types of providers).
Our submission therefore recommends that the future price setting decision maker for the NDIS should be an independent body that is established separately to the NDIA. Additionally, the NDIA should increase the pricing rate for therapy services delivered to remote and regional participants, remove caps on the amount of travel that can be billed, and make a commensurate increase in plan funds to adequately cover required travel.
The Paper also proposes that rather than ‘rewarding’ NDIS providers for the volume of supports they deliver, payments should be based on outcomes achieved for participants. AHPA supports the goal of achieving best outcomes and value of supports for participants, but we do not support funding and payments being tied to measurement of value or outcomes. One reason is the likely implications for provider viability in a context where it is already very difficult for many participants to access the diverse range of therapy supports they need.
Instead, value and outcome measurement should be adopted by NDIS providers and regulators as a matter of course. In the case of allied health professions, AHPA’s members are already either regulated by the Australian Health Practitioner Regulation Agency, or are self-regulating to an equivalent standard. That means that the diverse forms of allied health professional practice are already evidence-based, and are therefore predisposed toward working to develop best practice approaches to high value care and outcome measurement.
The NDIA should therefore work with therapy support providers and NDIS participants to develop information and guidelines about best practice therapy supports that help participants achieve their goals. This work must also incorporate and collaborate with outcome measurement, digital integration and workforce planning projects already begun in other care and support sectors, so that interoperability and system-wide data collection capacity is assured.
Further detail is available in our submission.