Planning for NDIS 2.0 – Stop needing to prioritise the bushfires, use the upcoming caretaker period to proactively backburn. 

“Failing to plan, is planning to fail”.

If you thought NDIS 2024 was a wild ride, strap yourself in for NDIS 2025. With a caretaker period looming:

• NOW is the calm before the storm.

• NOW is your opportunity to plan how you will survive the NDIS death by 1000 cuts.

• NOW is your chance to secure your own future and ensure the people you support have every possible opportunity to thrive.

We already know the following landscape looks like:

• The Fraud Fusion Taskforce will continue to chase $1.3 billion in alleged outstanding NDIS fraudulent claims.

• There will be continued crack downs designed to limit the cross over of services within the different government departments. So, whilst people with disability are meant to be in the centre of everything we do, they will just be placed in different environments and expected to adapt.

• By April, we will likely have greater clarity on the NDIS Quality and Safeguards Commissions’ new powers to increase financial penalties as well as the ability to initiate criminal charges against NDIS key personnel for breaches of the NDIS Act 2013.

• By May, the Independent Hospital and Aged Care Pricing Authority (IHACPA) will be submitting their proposal to the Australian Government about the current approach to pricing and future reforms.

• What we know so far is:

  • They are looking to have different prices but align the pricing methodologies to Aged Care.

  • If IHACPA take over, providers will have to make significant effort to break down and understand what their costs are. By this I don’t just mean budget but how does each position in the organisation generate of protect the value offered to the NDIS participant.

• By June, there could be a new definition of what a provider is.

• By July, we will likely receive guidance on when and how will Supported Independent Living (SIL) Support Coordinators and Platform providers will need to be registered.

• By October, we will likely have new Practice Standards.

That’s a lot to take in!

So how did we get here and where do we go from here?

My personal view is that we have been in a significant state of flux for at least the last 3 years (or maybe 13 years). The honeymoon period wore off and we kept waiting for a stable operating environment, but the ground hasn’t stop shifting and an acceptable “new normal” hasn’t emerged.

It is human nature that people tend to adapt by withdrawing into helplessness or lapsing into cynicism (is this resonating?) but the tendency to withdraw is something we leaders need to fight against. Being “stuck” serves nobody well.

“If you continue to prioritise the bushfires, without proactive backburning, you will eventually be in the middle of a catastrophe”.

I know you’re busy, but taking time to plan strategically will give you and the organisation a stronger edge for success as providers.

Risk, liability and adaptability

As capable service providers, you are carrying the financial burden to try to prevent things from going wrong, but you will still be the one getting the fingers pointed at when they do but, in this environment, you have more agency than you realise.

Think back to February 2020. It was inconceivable that we would have locked down homes, implemented mandatory staff vaccination policies and developed crisis protocols because of a virus. Disability as a portfolio was often overlooked in government decisions and we were forced to use our collective intelligence to attack what was a catastrophic problem.

The road ahead…

Knowing that we survived the collective challenge of the pandemic, we can, and should, feel confident that we will make it through the new challenges that we’re facing now.

So now Supporting Potential is issuing a challenge to the NDIS Service Provider Leaders….

“Focus on the impact you can create, not the chaos you can’t control.”

Again, the government will not save you. You need to save yourselves and your organisations by viewing the next an opportunity to experiment and challenge assumptions that no longer serve you well.

We are going to go on this journey with you every step of the way. We will be issuing a series of fortnightly blogs and webinars addressing common pain points in the current environment and providing suggestions on how you can successfully navigate future complexities without losing momentum.

Our simple approach will give you take away tools to be able to review and revise your strategy for the next 12 months.

 

The Survive & Thrive: Your NDIS Growth & Sustainability Guide topics we will be covering are:

Part 1 . Your NDIS Growth and Sustainability Guide overview

This article, which provides an overview of the current NDIS landscape and upcoming challenges.

Part 2 . Planning for NDIS success will be dependent on your approach to change

2025 will be pivotal for providers with:

• • shifting participant needs

  • regulatory changes

  • the expansion of liability, criminal charges and civil penalties for individuals and

  • the increasing demand for personalised, high-quality supports

The traditional “set-and-forget” planning models that highlight ‘quality’ service and growth, will no longer suffice.

Outcome – understanding your natural tendency to change will directly affect how your organisation needs to approach 2025

Part 3. Who has a seat at your NDIS Strategic table?

Does your organisation have the right expertise and experience to map the next 12 months as well as responding to what is needed right now? Remembering if you do what you have always done, you will get what you have always gotten.

Outcome – identifying and mobilising your core contributors for future transformation and how to best structure your change management approach.

Part 4. The mirror not the microscope

Revisiting what you as the leader and the broader organisation stand for. Is it intrinsically understood and evidenced? Simply put are you walking your talk?

Outcome – to build or reaffirm confidence, clarity and consistency about your purpose to help the organisation and its stakeholders to identify common ground and negotiate the continued chaos.

Part 5. The microscope not mantra

All service providers essentially want to deliver a service that is valued by the NDIS participants and to provide an environment where people want to belong. But how is this translating to your daily service delivery?

Outcome – a gap analysis of what you do well, what you need to improve on and what is not worth your time or energy.

Part 6. Money matters

In human services, cost is mostly driven by our people. We will seek to understand the linkages between cost, value and price and how this should impact your budgeting approach, ensuring you maintain financial sustainability while delivering quality services. We will also dive into the likely impacts if IHACPA take over pricing to support you to mobilise quickly to the likely changes.

Outcome – the development of organisational strategies to optimise financial results in a price restricted environment.

Part 7. Structuring your approach to risk

This could be your new competitive advantage as well as your best approach to staying out of court, and out of the public eye for the wrong reasons. We review the different requirements of risk management from the Federal Court outcomes of Commissioner of the NDIS Quality and Safeguards Commission v Valmar Support Services Ltd [2025] FCA 11 and Commissioner v LiveBetter Services Ltd [2024] FCA 374 (LiveBetter)

Outcome – a clearer picture of where your key risks likely lie and the development of core mitigation strategies.

Part 8. Reframing compliance to be your competitive advantage

Mandatory registration will mean being registered is no longer a quality indicator. How are you going to adapt to new Practice Standards quicky whilst developing data that proves the quality is being delivered?

Outcome – the development of a mobilisation plan which identifies how changes to the Practice Standards might impact your operations, and how you will shift your approach to support efficient and effective quality.

Part 9. Communication is King

How will you communicate with your broader team? All storms eventually pass, you need to understand how you will build resilience within yourself, your team and the organisation.

Outcome – a documented communications and outcome plan designed to provide clarity amidst chaos, build and strengthen resilience, and reduce resistance to change management.

Part 10. Identify, plan, monitor, pivot and know where it is safe to fail

For all the great ideas out there, you are only as good as your implementation.

Great ideas are only as powerful as their execution. Remember— what you can measure, you can improve.

Outcome – strategic implementation plans and key indicators of success.

 

And finally….

Take some time to have a look at our recent webinar “From the Courtroom to the Boardroom – What you need to learn from NDIS case law to manage your risk “ You won’t want to miss this! 

NDIS Growth and Sustainability is achievable!!

This essential survival guide blog series offers actionable guidance so that you can implement a structured approach within your own organisation in small and manageable parts. But sometimes, this can be difficult to achieve in practice and you need to have external support as well as internal.

We can provide facilitated, short and routine sessions to support you not just navigate the ongoing NDIS changes, but to create a competitive advantage that will serve you long into the future. You can also engage our executive support for the next 12 months, with packages to suit every stage or organisational aspiration.

If either of these options are of interest to you, we’d love to hear from you. You can contact us via email angela@supportingpotential.com.au or schedule a time to have a chat via my bookings calendar.

 

Get involved…

We’ll be sharing practical tips, real life examples, and expert insights every week.

Follow along, join the conversation, and share these posts with your network. Let’s build a stronger, more adaptable NDIS community together.

I look forward to ‘seeing you’ again next week!

 

Your partner in achieving compliance, growth and sustainability 

Angela Harvey

Managing Director of Supporting Potential

To read all our other blogs visit here.

Tuesday 3 December 2024 is International Day of People with Disability. Many orgs will likely put a social media post up or maybe share some cupcakes. But what does it really mean and why is now the time to build your movement?

This may be controversial, but I feel it needs to be said.

People with disability are not special. They are people with unique skills and presentations. The reason they need a special day is because, as a society, we have historically excluded them from the ‘mainstream’. All the leadership theories currently state you should support each member of your team as an individual. You are part of a superior organisation, meaning you already have this as part of your ethos. So this article is simply about the incremental changes you can make to ensure people with disability are included at every step of their journey with you, be that contributing to your corporate outcomes or purchasing your organisational outputs.

My challenge to you is how can International Day of People with Disability (IDPwD) be used as a springboard for long-term, meaningful change rather than a one-off event.

Never has there been a better opportunity for organizations to take the first step in creating sustainable disability inclusion practices and experience the business, social, and cultural benefits of disability inclusion. Did you know a Nielsen report highlighted that one in four households included at least one person with a disability. This is a broad consumer base with diverse needs and preferences.  By offering accessible products, services and employment opportunities, businesses can tap into this market, enhancing customer loyalty and expanding their reach.  Or more precisely, approximately 4.4 million Australians live with a disability, accounting for 17.7% of the population. Consider this number plus their families and caregivers and it becomes an obvious economic strategy to better serve this market.

Steps for your disability inclusion movement:

Many organisations fear inclusion processes. Our human nature wants to protect ourselves at all costs. This means we avoid facing our privilege as it might show a reflection that is different to the stories we have told ourselves. Then we start thinking well this might be too big a problem for me or my company to fix. You don’t have to fix it. But you do need to play a role in the solution.

Inclusion starts with listening:

• Advocate for IDPwD to be a day when organizations commit to listening to the voices of people with disabilities. This could include hosting panels, conducting surveys, or engaging with employees and clients with lived experience.
• Look at your data on disability. And if you don’t have data ask why?  If 1 in 5 Australians have a disability and your workforce is not representative of this why?
• You will likely have more people with disability in your ranks than you realise. Those people may have a lot more to give if small accommodations could be provided.

Small Steps, Big Impact:

Simple actions can serve as a foundation for your disability inclusion campaign:

1. Build a roadmap for transforming conversations into measurable goals. This needs to be unique to your organisation and your position on the disability inclusion spectrum, our disability inclusion quiz may be a great starting point for you. But most organisations could consider key milestones like:

• • January: Accessibility audits. We can help you with our engaging lived experience walk through. Many of the Supporting Potential lived experience advisors have complex needs. By seeking their guidance and input, you will be more likely to accomodate all people with disabilities.
  • March: Staff training on disability inclusion. Hiring people with disability without first building a safe environment for them to bring their full selves to work will likely hurt your inclusion efforts. Providing insights into the social model of disability and putting real people to the stereotype images can have huge impacts. Our empathy enhanced training has shown significant behaviour changes in acceptance and willingness to accomodate reasonable requests for adjustments
  • July: Recruitment of people with disabilities. Most adjustments cost very little money. It just takes a different approach. Several of the Supporting Potential lived experience advisors have an intellectual disability. They have great insights but can often struggle to convert this to writing in order to fit with existing operating models. But they can speak their ideas excellently. By providing chat to text apps, they can contribute just as much as anyone else on the team and can sometimes do this more efficiently.

2. Then on international day of people with disability 2025, it’s time to Celebrate and Reflect:

Use IDPwD to publicly celebrate contributions of employees with disabilities, but also set the tone for reflecting on areas for growth. It’s key to be transparent about your journey. You won’t be achieving perfection in a year but you can inspire confidence and accountability for further improvement moving forward.

So what’s stopping you from starting? Small, conscious efforts will allow you to better embrace accessibility and inclusivity, supporting you to unlock new markets, drive innovation, and contribute to a more equitable society.

 

To read all our other blogs visit here.

I have been a little quiet on the blog front lately. This wasn’t a deliberate decision, but now looking back, I think I needed time to reflect on all the noise to be able to really consider the changes. I think it’s where I got a bit lost and frankly overwhelmed. And I think the key driver of that feeling was the simple fact is a shift is imminent, but the outcome is still ill-defined, and the path remains murkier than ever.

I have been developing content for our Rising Leader’s training program and the reasons for my feelings were staring me in the face (do as I say not as I do, right?).

Using change management gives confidence

We don’t know what the future state should look like. Hell, sometimes we don’t even know what the current state should be. This uncertainty kicks us into a physiological reaction for fight, flight or freeze. I believe many people in our sector have been like me, frozen.

So once again, I thought ‘practice what you preach’ and looked to the self-awareness module. When we feel overwhelmed, it helps to focus on the facts and influencing factors, such as:

1. There has never, in Australia’s history, been a bigger financial investment in supporting people with disability to live their ordinary life
2. The financial modelling of the NDIS has always been flawed and the rhetoric surrounding the cost of the scheme creates panic
3. People were able to achieve good outcomes on the state-based support schemes. More people have been able to achieve good outcomes in the first decade of NDIS. Good will continue to be done
4. The NDIS is a complex system made of many interconnected parts that is ever evolving

I read an interesting article from the Human Systems Dynamics Institute about the baker’s transformation. The baker’s transformation is built on the concept of kneading dough (stretching, folding, stretching, folding). First, you need to ‘stretch’ and expand, seeking out new knowledge and explore opportunities. Then, you need to strengthen by ‘folding’ and blending the new with the existing, allowing space for reflection and rest. It is essentially a model used in situations where change is inevitable, but the pathway to achieving that change is still uncertain. This model recognises that while we may have clarity about the need for transformation, the specifics of how it will unfold are often still evolving.

In my experience, service providers know that they need to adjust their practices. For some it is to meet new regulatory standards, for others it is to remain financially viable with price guide ‘cuts’ and others may be seeing the increased demand for person-centred care. But a common feature is many don’t yet have a concrete roadmap for how to make those changes. Similar to providing positive behaviour support, the baker’s transformation provides a framework for managing uncertainty through iterative progress, team alignment, and continuous learning.

It’s too easy to fall into the trap of either delaying change until all the answers are clear or rushing ahead without adequate preparation. The baker’s transformation balances both extremes, allowing service providers to move forward confidently even when the ‘how’ isn’t fully known.

So, if you are an executive leader, pause reading and get out your strategic plan. You want to be able to cross reference these points and think about them from a change management perspective.

1. Focus on the destination, not the pathway

At its core, the baker’s transformation emphasises understanding the ultimate goal of change, even when the process is still in flux.

Are you clear about the goals you want to achieve? And by clear I don’t mean generic goals of:

• delivering better client outcomes,
• improving operational efficiency, or
• ensuring compliance with the NDIS Practice Standards.

Action Step: Begin by being specific about what your service is aiming to achieve. For example:

• greater participant retention by having less than 5% of participants transition out of our services within the next 12 months, or
• more efficient service delivery by measuring the contribution made by each individual in the organisation and then comparing it to the mission of the organisation, or
• improved staff retention of less than 15% turnover per annum and status as an employer of choice, or
• increase the representation of people with disability in fully paid employment within our organisation to at least 18% of our workforce.

2. Iterate through change

Instead of waiting for a perfect plan, the baker’s transformation encourages organisations to iterate, experimenting with small changes and adjusting based on feedback and results. This approach is especially useful for NDIS providers who often face regulatory changes or shifts in participant needs.

Action Step: Implement a cycle of ‘plan, do, review, adjust’. Start small—whether piloting a new service delivery model in one area or testing new communication technologies for supporting participants with complex communication needs. Use data from these trials to inform broader changes.

3. Empower your workforce

Change management in NDIS services can only succeed if the frontline workforce is prepared, empowered, and engaged. To do this they must feel well supported. Reflect on your middle management team for a moment. How many of your middle managers, who have been in their positions for over 2 years, are likely to feel trapped by administrative duties and hindered by their lack of authority to implement changes? A core aspect of the baker’s transformation is involving your team in the journey of change, encouraging flexibility and creative problem-solving.

Action Step: Develop open communication channels and regular feedback loops with your team. Share the overall vision but empower your frontline workers to experiment with how to achieve these changes. This creates a sense of ownership and responsibility across all levels of the organisation, improving buy-in.

4. Adapt to emerging challenges

Our sector is inherently dynamic. Shifts in government policy, participant needs, or broader societal changes can make it difficult to stick to a fixed roadmap. The baker’s transformation emphasises flexibility—being able to pivot quickly when necessary. How many of your strategies and services look similar to what they were before Covid? Additionally, you can’t win a war fighting on too many fronts, so spend time identifying what are the two to three likely scenarios that will have the most material effect on your organisation.

Action step: Foster a culture of agility within your organisation. Encourage leaders and workers alike to regularly assess the external environment and make adjustments as needed. For example, as new NDIS rules emerge regarding high intensity supports, identify who and then the how for quickly updating and implementing your internal training and service protocols, and then seek to refine.

5. Continuous learning

In times of change, learning needs to be embedded into the daily fabric of NDIS service delivery. The baker’s transformation promotes a mindset of continuous learning, where every challenge is an opportunity to improve and refine practices.

Action Step: Build regular reflection into your operations. Whether through team meetings, participant feedback, or performance metrics, ensure your organisation is constantly evaluating what works and what doesn’t, and making adjustments accordingly. This may mean hearing things you don’t want to. But as my seven-year-old reminds me “mistakes are proof of trying”.

Final thoughts

For NDIS service providers, change is not just frequent; it’s essential to be sustainable in a complex and highly regulated environment. As the late Brazilian car-racing champion Ayrton Senna once said, “You cannot overtake 15 cars in sunny weather, but you can when it’s raining.” So, the choice is now yours, fight, flight or freeze?

Feel free to book in for a confidential, no obligation chat, if any aspect of this article has peaked your interest https://calendly.com/angela-supportingpotential/consulting-fact-finding

 

To read all our other blogs visit here.

In the light of the recent price guide and the rhetoric that quality will suffer, we are going to continue our analysis of the current litigation against NDIS Service Providers (part 1 available here)  We have to remain vigilant on the quality and safeguarding mechanisms we are implementing. We must think about how we can achieve better quality outcomes with less financial impost. The longevity of our organisations and more importantly the people receiving supports depend on it.

NDIS service provider #2

Ms KL was a young (28-year-old) Indigenous Australian woman, who lived with her Family in Orange NSW. On 2 February 2022, KL sustained burns to 35 to 40% of her body while receiving bathing support services from Organisation 2. Tragically, five days after this bath, KL passed away in Hospital. The medical records refer to her death as being caused by burns.

KL had Cornelia de Lange Syndrome, intellectual disability and other health conditions. She could have difficulty regulating her temperature, was prone to eczema, had minimal subcutaneous fat and muscle, and her skin became infected from time to time. She was small in stature, unable to independently mobilise herself, and non-verbal (but could be vocal).

KL had been receiving services from Organisation 2 for over 11 years. The services changed over the years, but in prior this horrific incident she was receiving:

• Personal care and bathing support (started April 2021)
• Community access and day program support between 9:00 am to 3:00 pm Monday through Friday and 10:00 am to 4:00 pm on Saturday for a period of 10 weeks,
• Respite support.
• Domestic assistance.

Organisation 2 provided bathing support to KL, without incident, 80 times. Each occasion had two workers were present.

To support KL, Organisation 2 had the following documents:

(a) a “Safe Work Client Manual Handling Plan” dated 25 May 2016;

(b) a “Client Risk Profile” dated 5 April 2017; and

(c) an “Interim Behaviour Support Plan” dated November 2021

None of the risk assessments identified risks arising during bathing supports, specifically the risk that water can be hot and someone may get burnt. Therefore, they were deemed not adequate to manage the risk present.

On the day in question, one of the workers ran the hot water tap in the bath then added cold water for approximately 1–2 minutes. She then scooped her bare hand in the bath water (closer to the tap than the side of the bath) to check the temperature. She considered the temperature to be fine and did not observe steam coming off of the water.

Taking this into account, the courts found that whilst Organisation 2 did provide some training and competency assessment to staff, it was not adequate. The competency question was too vague as it did not specify that the correct water temperature of the bath or shower is up to a maximum of 40 degrees Celsius.

Organisation 2 was fined $1.8 million for their failing to meet the NDIS Act.

As the provider of a training and competency assessment tool, this case gave me pause. How complex were the questions we were asking staff? Did it really identify if they had learnt something or were they just going with the obvious answer? We have now changed all of our questions to ensure you can have confidence that you team have LEARNT and not just completed your online learning. I urge you to review your learning management system and make an assessment. IF something bad occurred in your service, are you confident that you have trained staff well?

The second area of pause for service providers with this case, is that it wasn’t the absence of support documentation that they were fined for. It was the absences of documenting a single risk. I have always taken the view with disability service risk assessments that if it is a risk for a member of the general public then standard precautions apply and it does not need to be documented. Admittedly, in KL’s case, she had additional needs which increased the risk of hot water burns, so I hope I would of addressed it. But once again, Providers need to review their risk assessments to ensure they have appropriate measures in place for all risks relating to their service provision. That final part is critical as you will spend forever risk assessing if you haven’t clearly defined the services being receive.

NDIS service provider #3

Mr G. had an intellectual disability, tuberous sclerosis, epilepsy, adenoma sebaceum and obstructive sleep apnoea. He died on 17 March 2023, when he was 38 years-old, having been hit by motor vehicle after leaving his supported independent living residence alone some time after one am. Despite two to one active support, he was able to leave without the knowledge of the two support workers with him that night. It is alleged that one support workers had fallen asleep whilst the other heard the back door open but did not investigate further

The Allegation from the commission is; “It is alleged that Organisation 3 failed to provide supports and services in a safe and competent manner with due care and skill, resulting in harm causing death,” It is also alleged that the service provider was restricting Mr G’s access to Pepsi and television and that this was likely a trigger for Mr G.to engage in harmful behaviours.

The judgement handed down on 26 June 2024, allows the NDIS Quality and safeguards commission to continue to investigate this incident with the view of further court proceedings, despite the provider going into liquidation. The reasons for this judgment were:

• In the public interest of compliance to the NDIS Act
• Protecting and promoting the interests of NDIS Participants generally
• Promoting the deterrence of conduct which contravenes the NDIS Act
• Vindicating a public right that has been breeched
• Addressing particular conduct that may have contravened the NDIS Act.

 

The Judge is quoted as stating “the respondent’s alleged failure to provide services to Mr G.in accordance with the conditions of its registration as a NDIS provider caused harm of the utmost seriousness to a person of disability who, by virtue of his disabilities, required protection from harm”.

The last part of the sentence concerns me as it re-shapes the duty of care Vs dignity of risk debate. All humans should be protected from harm by others. Vulnerable people like those with disability, older people or children, require a higher threshold and coaching to support successfully approaching possible danger. But to simply state because of disability you require protection from harm, I think it minimises the rights and autonomy of the person with disability.

We still don’t know a lot of the details of this case as it hasn’t been fully presented to the courts, However, services providers should take note:

• Unauthorised use of restrictive practices WILL be prosecuted, particularly if the person has come to harm. Even if there isn’t clear linkage between the two
• As a service provider, how do you ensure your staff are not being restrictive in the way they provide daily supports.
• As a service provider, how do you ensure staff efficiently do the job they are paid to do. As an investigator and HR Exec, I have conducted hundreds of reviews into staff sleeping on shift. And that only the ones that have been found out.

 

The nature of community living means that SIL services are going to be spread out. You are not going to have supervision at all moments and people do dumb stuff.

This case demonstrates the challenges of distant service provision. The SCHADS award (and the NDIS) advocate that support work does not require high education or special skills. We are entrusting this working group to deliver effective supports, often unsupervised. The nature of this is unlikely to change. But, I have long advocated for a “don’t be a dickhead policy” and been wisely advised against it. However, there is something to be said for providing all staff with directions on what a reasonable days work looks like for example, do not fall asleep whilst on shift. This then needs to be supplemented with training for the frontline employee to enhance their understanding and training for the leaders, to identify behaviour slippage and correct (AND Document) before its too late.

The underlying theme to these cases is that in Human Services, things are going wrong far more often than they should and the consequences are devastating. Not just for the families of MA, KL and Mr G. and others like them, but I would imagine the staff involved will also carry the burden of the impact of their ineffectiveness.

It is easy to vilify the providers involved, but the root cause of these tragedies is far more complex and multifaceted. To help you sleep at night, we can assist you to do a full orgainsational risk assessment. One that is tailored to you and the needs of the people receiving your services. We will balance these against you fair work and safe work risks for supporting your team. We will then work with you to identify streamlined ways to continue to identify and mitigate risks in your service delivery.

With all the chaos and noise in the sector right now, the one guarantee we have for the future is that good quality and safe supports are critical to doing business in the disability sector.

 

To read all our other blogs visit here.

The Australian Government has released their formal response to the Royal Commission into violence, abuse neglect, exploitation and discrimination against people with disability. And LinkedIn has been ablaze. Words like:

• Gutless
• Lacklustre
• Disappointing
• Underwhelming

The cynic in me views the 306-page response as a wonderful piece of advertising material for the Labour Government. It’s an ode to look at all the great things we have ‘proactively’ done to meet the recommendations for the Royal Commission. Everything else we are just going to keep kicking the can further down the road, but keep reminding you how committed we are.

This blog isn’t going to focus on the individual recommendations from the Commission and the Governments response. You can find that in the government summary. Instead it is going to focus on the process and the actions that have been committed to, whilst comparing to behavours that have been demonstrated (no I’m not a behaviour support prac).

 

The final report on the Disability Royal Commission was handed down in September last year. The Government was due to provide a response in March of this year, but delayed. They stated it was complex and they needed to do public consultation and complex issues required more detailed analysis. So 10 months later, they have developed a response based on public consultation that garnered 335 questionnaire responses and 118 written submissions. Assuming each of those was an individual and one entity hasn’t done multiple responses, they have received ‘public consultation from 0.01% of the population with disability. Or if we want to be more generous 4.5% of the number of people that shared their trauma with the commission.

 

Pages of the response document were spent rehashing budget allocations. $371 million has been allocated in the budget. But there is very little rigour around what that money will actually buy. For example the government as committed $12.3 million to improve national approaches to accessible information and communications, including Auslan. Yet the media briefing did not include an Auslan interpreter in the shot. Nor has the government insisted on putting in closed captions when televised or replayed. $12.3 million is a lot of money when the simple action of providing news about people with disability and for people with disability is overlooked.

We work with many mainstream organisations on how to improve disability inclusion. Our answer is you don’t have to throw a lot of money at it. Your small, but continuous gestures which reduce stigma and foster inclusion will be far better received that grand aspirations with no tangible improvements felt.

 

My key takeaways from reading this propaganda is:

• No risk profile model. There is a large focus on people identified as being at heightened risk of violence, abuse, neglect or exploitation, particularly those living in supported accommodation and channelling dollars and additional support to this group. But within the document the government has confirmed that they are yet to design a Risk Profile Model to better identify NDIS participants who may be at risk of harm and are likely to need comprehensive individualised response strategies. For example by 30 September 2025, this cohort of people at heightened risk are meant to have support coordination included in their NDIS plans, with sufficient funding to facilitate face-to-face contact at least monthly. How can you build this into a person’s plan, if you cant identify who the person is?
• The government has made a commitment to preventing conflicts of interest in support coordination, it reads as though the exception might be where there are thin markets. However they have also committed to the implementation of Navigators stating, “All governments are committed to working together to support the development of a nationally consistent health navigation framework, which will be coordinated and aligned to complement the reshaped disability navigation function of the NDIS and would include scoping of disability health navigation in partnership with state and territory governments”. So Support Coordinators and the people they support are still in the dark about what the future is likely to hold in that space
• A commitment to following through on the legal separation between SDA and SIL. They didn’t state if this would apply to ensuring ownership / directors couldn’t be the same across different companies.
• The jury is still out on a national disability support worker registration scheme, noting “The NDIS Provider and Worker Registration Taskforce will provide a report with advice and recommendations to Government in mid-2024”.
• There will be no pay rise under SCHADS, the government has instead deferred to a review by the independent Fair Work Commission to consider possible gender-based undervaluation in certain priority modern awards, including the SCHADS Award.
• Implementation of class or kind determinations to allow the commission to manage the volume of reportable incidents. This could be a big one for registered providers who diligently report their incidents. Historically, all reporting and investigating does put your neck on the chopping block. It would be nice to see some credit go to the organisations that are committed to investigating and making changes when things go wrong.
• The government stays commitment to the National Disability Data Asset but there is currently no commitment to fund it beyond 2025, suggesting this needs to be negotiated with states. This tells me that it will stay live but how useful or beneficial it will be, time will tell.
• We don’t need a Minister for Disability as “The Australian Government supports strong national leadership on disability policy and programs. The Government currently has two Cabinet positions with responsibility for national disability policies and programs: The Minister for Social Services and the Minister for the National Disability Insurance Scheme (NDIS)”.
• Restrictive practices = bad. The government is committed to the reduction of restrictive practices but not understanding why they are used and how to safely address the root cause. Strengthening the evidence base on reducing and eliminating restrictive practices. They don’t want to conduct a longitudinal study, stating “would impose significant methodological challenges and may pose risks to study participants”, but then wants to establish targets and performance indicators. Once again, how can you develop reasonable targets and metrics without understanding and fixing the underlying drivers. This approach to me is riddled with risk for people at high risk of violence. Restrictive practices wont stop, but the recording of it might if there is incentive enough to do so.
• Supported / substitute decision making. Given how pivotal this is in ensuring human rights, I was shocked to find the government was fairly silent on this recommendation. Once again states they’re committed but no action or outcomes. It reads that they have this covered due to their commitment and recognising that substitute decision making is only a last resort. But anyone who has dealt with the Office of the public guardian will tell you that this has not been addressed.
• Group home reform was one of the contentious issues in the Commissions final report. And it has not gotten cleared. Instead, the government has committed $49.7 million for design and consultation to support better home and living options for NDIS participants. The measure includes targeted compliance activities and an education campaign to ensure Specialist Disability Accommodation (SDA) providers are aware of and meeting their existing conflict of interest obligations. Not to be negative, but we have been here before with the NDIA holding rounds of innovative housing models, but there is yet to be a tangible way that people can access alternative models or that service providers can fund. ILO is still being critically underutalised, my guess is because LACS and Planners don’t understand it. The continue focus on SDA providers is also alarming as this only applies to a cohort of people requiring home and living supports.

 

The report closes by stating

“All jurisdictions have agreed to the National Disability Royal Commission Monitoring and Reporting Framework (the Framework). The Framework outlines arrangements for governance and the ongoing monitoring of implementation progress of all reforms in response to the Royal Commission. A web page dedicated to reporting on the implementation of the Disability Royal Commission recommendations will be developed and managed by the Department of Social Services”.

Once again, this just seems like words on a page and not dedicated action. It has been 10 months. I have built (with tech support of course) a website in 10 hours…… This would have been a nice touch if it was ready to go. Or at the very least a time commitment for it being live. And lets not forget some of the background noise. Mr Shorten has attempted to push through new NDIS Legislation quickly and without a lot of consultation on the basis that this can come later. Yet the enactment of a Disability Rights act, is subject to further consideration. Stating “This will ensure a holistic approach is taken to ensuring the rights and freedoms of all Australians are respected and protected”. Should the same liberty not be awarded to the 600,000+ on the NDIS and the families and service providers that support them?

Words are cheap especially regarding disability rights.

But actions are real and there was very little concrete action which could be measured and reported on. This macro response provides very few decisions that allow us to predict the values and standards we are going to hold our government accountable to. I would love to see a supporting document that is focused on the next 12 months, and the micro actions. What specifically will be done to ensure that Australians with disability and their supporters are not just left with good intentions.

 

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In today’s fast paced, high tech and rapidly changing world, our brains have to rely on a whole bunch of shortcuts so that we can make decisions (like should I get out of bed). Our brains truly are amazing. It can form associations between different concepts based on past experiences without us even realising that’s what we have done. These associations can influence our perceptions and actions without us being aware of them. This can be known as unconscious bias or implicit bias.

It is not uncommon for people to have at least one (if not all) of these unconscious biases surrounding disability inclusion:

• I don’t give need to worry about people with disability as it doesn’t impact me
• Disability inclusion is currently the buzz in the business world and we can do our bit with a cute morning tea
• Disability inclusion is a “special project” that is done in addition to your normal day job vs a strategic objective that shapes how your business operates
• You have successfully navigated disability inclusion if your business meets the building accessibility requirements. But did you know a disability bathroom may meet the standards and still be totally inaccessible to a person in a wheelchair as they can’t navigate opening the door.
• Disability inclusion is fought with risk. If we get this wrong, we will be on the cover of the newspaper

Unfortunately these unconscious biases prevent us from taking simple actions to improve the world for many people.

One tool to get you closer to dispelling an unconscious bias is having a workplace adjustments policy.

Very simply a workplace adjustment policy tells staff that you want to remove the barriers that may prevent them from performing at the top of their ability. Reasonable adjustments don’t have to apply to just people with a disability. It helps everyone to bring their best selves to work each day. Some common examples of workplace adjustment are:

• Physical modifications to the workplace (e.g., ramps, adjustable desks).
• Assistive technology and equipment (e.g., screen readers, ergonomic chairs).
• Flexible work arrangements (e.g., part-time work, modified hours).
• Provision of auxiliary aids and services (e.g., interpreters, note-takers).
• Job restructuring or task reallocation

Despite this simple definition, many people with disability often will not ask for a workplace adjustment. Some of the reasons I have heard are:

• I don’t want to lose my job
• I don’t want to be treated differently
• I don’t want to be seen as a ‘princess’
• It’s just easier to organise the adjustment myself
• My employer doesn’t have the right to know I have a disability as it doesn’t impact my job.

By having a clear and concise policy, you send the subliminal message that asking for an adjustment is ok here. That is not only the feel good part but it is also a legal requirement. The Disability Discrimination Act (1992). This legislation states:

Australian Organisations must “ensure that workplace barriers are removed so that skilled people with disabilities are able to perform the inherent requirements of their positions. To facilitate this, employers are required to provide reasonable adjustments within the workplace whenever it is necessary, reasonable, and possible to do so”.

Despite the legal driver, some business will still avoid engaging with workplace adjustments, some of the reasons being:

• We don’t have many people with disability who need reasonable adjustments
• It would cost too much
• It means we treat our staff differently and we don’t want to be seen to have favourites

Your workplace adjustment policy should include the following detail:

Purpose

We are committed to providing an inclusive and supportive work environment.

The policy is to ensure that all employees, including those with disabilities, have equal access to employment opportunities and can perform their role and individual duties effectively. This policy outlines the procedures for requesting and implementing reasonable adjustments in the workplace to accommodate employees with disabilities.

Legal Framework

This policy is guided by the following legislation:

• Disability Discrimination Act 1992 (DDA)
• Fair Work Act 2009
• Work Health and Safety Act 2011

The request process

Consider a streamlined and confidential approach that maps to other ways your employees may already operate – eg use your leave system.

Frame the request by starting with the barrier to performance and the expected outcome if that barrier were to be removed. Then ask the person to suggest options.

The assessment process

What factors will the organisation consider when deciding to approve the adjustment. Be specific with thresholds for:

• Improvement to be experienced by the person
• Proven effectiveness
• Feasibility
• Cost and whether subsidised programs such as the JobAccess Employment Assistance Fund (EAF), are applicable
• Impact on operations

Who will be making the assessment and what timeframes do they have to adhere to? Will the assessor come back to the applicant with other possible adjustments that may meet both the individuals need and the business need. Is there a process for appeal if you don’t agree with the decision. I am a personal believer that requests that don’t fit in with the thresholds identified above should be reviewed by a panel with reasons documented and shared with the applicant.

Monitoring and Review

How will the organisation ensure that the workplace adjustment is working in the way it was intended? What systemic reviews will the workplace do to identify if other policies should be adapted. For example, you may decide to change your procurement policy to ensure all future purchases meet accessibility standards, such as variable height desks.

Training and awareness

How will you ensure all staff know about this policy and can use it. Will you provide regular training and awareness programs for all employees on disability inclusion and the importance of reasonable adjustments?

 

This is all very simple to document in a blog, and if it was that easy, you would have done it by now. But it isn’t hard, sometimes you just need someone in your corner helping you with additional operational effort and specialist expertise. We can be that for you at Supporting Potential.

To read all our other blogs visit here.

The NDIS continues to be uncertain and turbulent. NDIS Providers are rallying for an increase to the price guide and the reintroduction of complex payments. But in my view, this isn’t the biggest crocodile in the water. It’s quite possibly the baby with the mumma lurking behind. The big croc in my opinion is the current litigation against NDIS Service Providers.

This article goes into detail about the untimely and tragic deaths of people with disability whist receiving supports. The focus of this article is to use publicly available information to look into the actions taken by the service providers and apply it to what is likely common practice, without retraumatising organisations or individuals connected to these cases. At no point do I intend to minimise the loss of these individuals but want to use their tragic story to create positive change for the future.

We also need to note that court rulings form precedent and precents becomes law. So lets dive into what we should know and apply to our services:

1. Organisation 1 (case study in this week’s blog) – Death in care, seizure management
2. Organisation 2 (case study in next week’s blog) – Death in care, bathing support
3. Organisation 3 (case study in next week’s blog) – Death in care, inattentive supervision

Organisation 1

The NDIS Participant (M) was nearly 21 years old. She loved Star Wars and 1980s hits. M had epilepsy and autism was receiving supported independent living from Afford. M sadly passed away on 23 May 2019 when she drowned in a bathtub. There were three residents at home and two staff, but neither of the staff were aware that M had epilepsy. M was left in the bath, unsupervised for approximately 25 minutes.

The courts found that Organsiation 1 failed to provide supports to M in a safe and competent manner. Specifically, they didn’t

1. Develop and implement adequate measures within the Epilepsy Management Plan specifically bathing or showering.
2. Develop an action plan to address the risks posed by M’s epilepsy, including the risks associated with having a seizure whilst bathing.
3. Ensure that M was adequately supervised, or adequate alternative risk management procedures were in place, whilst bathing on 23 May 2019.
4. Document M’s diagnoses and support needs in client records.
5. Take adequate steps to ensure that the support workers responsible for providing supports and services were made aware of any or all of the following:
   1. M was diagnosed with epilepsy.
   2. M could experience seizures.
   3. The terms of M’s Epilepsy management tool and/or Comprehensive Health Assessment Tool.
   4. Measures required to address the risks posed by M’s epilepsy whilst bathing, including a bathroom door with an internally lockable doorknob which could not be unlocked from the outside.

The Organisationshas owned their failings in this case, but I suspect the “failings’ are far more common in practice. How often, in this current staffing crisis have you placed an unoriented worker with a new NDIS Participant? Are any of your support plans out of date? How have you confirmed that staff are not only aware of their existence, but understand the steps they need to follow.

In essence, Organisation 1 did not follow their own procedures.

1. They had a buddy list checklist for new staff to demonstrate they had been shown how to provide supports with care and skill, this was not completed.
2. Their epilepsy policy identified steps to support a client with epilepsy whilst bathing, this was not followed.
3. They had risk assessment tools, but they were not completed correctly.
4. They had supported M to gain an epilepsy management plan and comprehensive health assessment, but did not complete the prompts within those documents to ensure she stayed safe

Organisation 1 was ordered to pay civil penalties to the Commonwealth totaling $400,000.

The Judges finding, which you can review here in detail  Commissioner of the NDIS Quality and Safeguards Commission v Australian Foundation for Disability [2023] FCA 629 (fedcourt.gov.au) states: “Organisation 1 had in place policies and procedures in respect of epilepsy and seizure management does not mitigate the conduct, as these matters did not prevent the patent failures occurring in this case. There is no point having such procedures and policies if they are not complied with”.

Which then begs the question, as an Executive, can you recall the different directives in your policies? If you can’t, how do you expect a frontline support worker to.

Policies need to be the foundation of a good organisation.  They set out how the organisation intends to meet legislation and regulation, but too often this is viewed primarily as an administrative task. Orgs buy off the shelf policies (which I support as a start, but then they need to be reviewed and adapted for your organisations size and complexity) or senior leaders state that its someone else’s role to develop that. The NDIS Quality Audit process was always designed to test HOW organisation embed their policy and procedures, but that’s an article for another day. I challenge executives to review their policies and procedures. How many pages are there? How many 3 syllable words are used. How many long sentences are there. Many support workers have limited education or may be from a non-english speaking background. This creates a bigger challenge for service providers.

We have seen huge successes with implementing our simple read work instructions. It’s a step up in terms of complexity from an easy read, but captures all the tasks that support workers are likely to encounter in their daily operations. It is done in simple English with images linking to the systems and tools used by the organisation.

Organisation 1 was precedent setting for the sector as it was the first provider that the NDIS Quality and Safeguards Commission brought civil proceedings against, learn from this sad example and don’t follow their mistakes. Next week we will be looking into the Organisation 2 and 3’s court findings.

When read together, these documents paint a bleak picture for organisations who rely on the “this is how we do it here and it worked so don’t change it” approach.

 

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This fortnight in the realm of NDIS we are not going to look at a single provider, but at the complex web of reviews, analysis and maintaining the status quo.

We have been assured time and time again that “The Government is dedicated to creating a safe and inclusive Australia, where all people with disability are supported to thrive”

But you would be forgiven for having head spins and not knowing who is doing what when and how. The last 12 months has seen a huge array of reports, recommendations and taskforces. Some of which are very loosely linked and make for one hell of a mess. The below table is my interpretation of what is going on:

Isn’t it interesting that the above nearly totals $1 billion, the same amount that is being investigated for fraud. The same amount it is going to cost to delay approving the new NDIS bill. So, by reducing unnecessary spending, coupled with fraud and a little bit of theatrics and we can save $3 billion. Just like that…

But nothing happens quickly in government. And this isn’t the first rodeo. We have had previous reviews of a similar nature.

The 2019 review of the NDIS Act by Mr David Tune, where all 29 of the recommendations were supported by government. The ‘tune review’ highlighted issues around ‘transparency’, ‘consistency’ and ‘timeliness in decision-making’, combined with many reports of subpar experiences when working with the NDIA.

Alarmingly the ‘every Australian counts’ campaign commented that the Tune review was  “singing to the same old tune” as what has already been well established, and let’s not forget to quote our NDIS Minister, Bill Shorten, who at the time was the Shadow Minister said, we didn’t need “yet another review to tell us that this Government’s neglect of the NDIS is hurting people with disability.”

For those that are interested, I have gone down the rabbit hole of actual actions in response to the Tune review and am happy to share, but this article is already too longwinded.

Getting down from my soapbox now, my question is how do you know where to start in the mess. The government can say “The proposed changes to the legislation are the start. They will enable design and testing of changes with people with disability as further improvements are made to the Scheme.” But that seems like a fairly blunt instrument.

I believe the government may have lost sight of the end goal. The uniting vision:

“An inclusive Australia is one that treats disability as a part of human diversity and understands disability itself as a diverse category”.

I suspect the path of least resistance that service providers create their own operating model which drives efficiencies, reduces your risk and allows you to survive with the changing price guide and other external drivers.

So, if your strategic plan looks anything similar to a version in the last 10 years then you will become collateral damage of the governments inefficiency. Contact us to book in an appointment to do your strategic planning differently.

 

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Did you know:

This is the current disability Pride flag

The disability pride flag was originally released in 2019. But… by 2021 it had to undergo an accessibility redesign. It was found the original design brought on symptoms such as seizures and migraines for individuals with visually triggered disabilities.

See, not even the disability sector gets disability inclusion and accessibility right all the time.

July is disability inclusion month. It is also the first month of a new FY so a chance to kick off those well-meaning projects which often lag behind the priority ones. Disability Pride month 2024 is the perfect time to start making your organisation more inclusive for people with disability!

Over the coming months, we are going to share a fortnightly update with tips and tricks for something you and your organisation can do to improve disability inclusion. In 2022, the Australian Disability Strategy implementation measurements suggested that 77% of employers were positive about hiring people with disability. Yet only 42% of Australian businesses reported feeling confident in their disability inclusion practices. With such a gap, this instalment will be focused on some myth busting and truth telling.

Research suggests that many organisations want to be disability inclusive, but don’t take action for a range of reasons:

• They think that it’s going to cost a lot of money
• They’re worried they will get it wrong and offend someone
• They wholehearted believe they treat everyone equally without realising the difference between equal and equality.
• They don’t have personal insight into why this is such a significant issue
• They have tried to be a more inclusive employer, but people with disability don’t apply

 

All of those are beliefs. And beliefs can be changed with lots of small but continuous improvements. To counter those beliefs, here are some quick-fire facts on why this is not only the right thing to do, but why it makes good business sense to do it now:

 

• People with Disabilities and their loved ones who make buying decision represent a huge, yet reasonably untapped market. Globally it is estimated to be 13 trillion dollars. In the USA the total after-tax disposable income for working-age people with disabilities is approximately $490 billion (Source: American Institutes for Research)
• Disability-inclusive companies are 28% more likely to have higher revenue, 30% higher economic profit margins, and 2x net income. (Source: Accenture Report: Getting to Equal)
• The Royal Commission into Violence, Abuse, Neglect, Exploitation and Discrimination of People with Disability has stated that the Australian federal, state and territory governments should leverage their buying power by adding disability inclusive employment practices to their procurement rules
• 1 in 3 People with Disability state that mainstream goods and services currently don’t meet their needs (Source: Australia Human Rights Commission)
• 33% of Australians with disability aged 15 and over, avoid situations because of their disability. One of the most common situations avoided were going to shops, banks etc. (34.3%). (Source: Australia Human Rights Commission)

 

Our first tip… be kind. Any action, no matter how small it may seem is better than no action. And you are probably doing better than you realise.

Second tip…. Understand where you are starting. You may be further along the disability inclusion journey than you might think.

Take this short quiz to find out where you are currently doing well and pinpoint the areas where you might need to invest some more effort.

How inclusive is your business for people with disability? (scoreapp.com)

 

Third tip… Keep trying even if you get something wrong.

Apologise, learn from the error and keep moving forward’. So long as you learn and correct the error moving forward, but to try and stop you from getting it wrong in the first place, here are some things the disability community want you to know (note this is a generalisation based on our knowledge as it is not possible to cover the views of every person with a disability)

• A disability is not a specific condition. Disability is as broad as the human condition.
• Focus on the person, not the disability
• Reference a person’s disability only when it’s relevant.
• Avoid pity terms, such as ‘suffers with’ or ‘afflicted by’. Having a disability does not mean having a lesser quality of life.
• People with disability often have a strong preference for either person-first language (people with disability) or identity-first language (disabled people). If in doubt, ask the person what they prefer, and being aussies, you can’t go wrong with a ‘mate’.

 

And the final tip for today….. Remember the rule of marginal gains?

Making consistent, small improvements can accumulate quickly and generate results better than could have been imagined. By reading this article and putting some of the tips into practice you have already slightly improved. The next step is to record your plan and achievements in an inclusion or organisational strategic plan as what you measure you will improve upon.

 

Our blog next fortnight will look at reasonable adjustments. Do you currently have a policy?

If you can’t wait for this information to come to your inbox each fortnight, get in contact with us for a confidential chat about where you are currently at and how you can get to where you want to be.

To read all our other blogs visit here.

So, it is the last working day of the financial year. Why would you expect more than 6 working hours of notice on what you can charge for your services in the new FY?

The headlines from the new NDIS price guide

1. There appears to be more robust rules on what is reasonable and necessary and claiming for ancillary services (but I haven’t deep dived here yet)
2. Standard support prices have increased 3.19%, but the SCHADS award has increased by 3.77%. The reason for the backwards movement appears to be the removal of the Temporary Transition Payment
3. For another year, there has been no increase to Support Coordination and Plan Management

New NDIS price guide:

We have quickly dug into the NDIS Direct Support Cost model to see how the Agency has developed the prices for next FY and I am not a mathematician (and would love to have this confirmed to me) but I have found a 1 cent discrepancy. I know that it’s likely to be a rounding issue, but you tell me, when you add up the FY24/25 direct worker costs do you get $48.62 or $48.63?

Table: Comparison of the FY 23-24 and the FY 24-25 Disability Support Worker Cost Model Assumptions and Methodology

I got the higher number but the cumulative impact actually makes it a 2 cent difference to the final price. Now I know my math skills are very crude, but I’m thinking that 1 cent difference to the hourly base direct support cost driver might save the government over $12 million next FY alone. Now that’s a lot of speech writers…

You do your own math, how may service hours are you likely to deliver this FY? Times that by 0.02 and you have the financial impact of this rounding issue to your org.

Now $12 million in a $40+ billion dollar scheme is hardly consequential. But when you already have 55% of providers reporting a loss (Stuart Brown, StewartBrown_-_FY23_Disability_Services_Financial_Benchmark_Report_final.pdf)

And the NDS State of the sector 2023 report stating:

We are worried we won’t be able to provide National Disability Insurance Scheme services at current pricing

Category	Disagree or strongly disagree	Neither agree nor disagree	Agree or strongly agree
Not for profit	14 percent	14 percent	72 percent
For Profit	22 percent	11 percent	67 percent

 

A 2 cent per hour reduction, based on rounding plus the removal of the Temporary Transition Payments that were introduced on July 1, 2019, combined with Super increasing up by .5% from July 1 and the industry rate for all insurances increasing; may see many providers finally slip into liquidation.

The TTP was originally designed to support registered NDIS providers during their transition to the NDIS market. It was meant to be temporary, but the impetus was to provide additional funding to help providers cover the costs associated with adjusting to the new pricing arrangements and regulatory requirements of the NDIS, ensuring they can continue delivering high-quality services while adapting to the new system. My question is – has the sector stabilised with the pricing and quality regime to state we are no longer in a period of transition?

Given we still don’t have a formal government response to the Disability Royal Commission or the Independent review of the NDIS, my guess is that only more changes are to come.

I welcome the NDIS review recommendation for pricing to be taken over by the Independent Hospital and Aged Care Pricing Authority. But the realist in me knows that is still a way away.

Providers need to take the future into their own hands now and look at how to adapt their services to the already lean margins. What can be automated? What can be streamlined? Where are you overservicing? How can you ringfence your quality and safeguards liability?

I don’t want to see more providers leave the sector. That goes against the original intention of strong markets and choice and control. But if there was ever a signal that you MUST start doing things differently. This price guide is it.

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