Improved Daily Living Review

Question from face book and response: Thanks Jason and risk Jedi, can you please send through the ndis source that states the minimum qualifications required for delivery of each of the IDL line items?

Thanks- good question. The NDIS Price Guide and Support Catalogue are the two primary sources of this information. Here is an extract: Therapy Supports (7 or older)

These support items provide therapeutic services to participants (7 or older). Therapy supports are for participants with an established disability to facilitate functional improvement, where maximum medical improvement has been reached. For people who access the Scheme as ‘early intervention’ participants, reasonable and necessary supports are likely to be a blend of medical and disability therapies but should be predominantly disability therapy supports. Therapy must be aimed at adjustment, adaption, and building capacity for community participation.

Maintenance care can be claimed against a participant’s plan, where the primary purpose is to provide ongoing support for a participant to maintain a level of functioning including long term therapy/support required to achieve small incremental gains or to prevent functional decline. In general, maintenance therapy that is reasonable and necessary should be delivered by carers who are or can be trained in this if required. Where a participant has a medical condition or disability that requires a particular regime to maintain functioning of a body part, or to slow the deterioration of a medical condition or body part, then these support items can be used to deliver reasonable and necessary training for non-qualified personnel to assist a participant, as part of usual daily care. These support items cannot be used for massage, delivered directly to impact a body part or body system, as these supports are more appropriately funded by the health system.

These support items can also be used for the assessment, planning, and delivery of Disability-Related Health Supports where these supports directly relate to a participant’s significant and permanent functional impairment and assist them to undertake activities of daily living.

These support items can be delivered to individual participants or to groups of participants subject to the rules set out in the NDIS Pricing Arrangements and Price Limits. In particular, these support items can only be delivered by the following types of professionals, and by therapy assistants operating under the delegation and supervision of one of the following types of professionals:

· Art Therapist – A person who is a Professional Member with the Australian, New Zealand and Asian Creative Arts Therapy Association (ANZACATA).

· Audiologist – A person who is either currently certified as an Audiology Australia Accredited Audiologist by Audiology Australia or as a Full Member as an audiologist with the Australian College of Audiology.

· Counsellor – A person who is either a member of the Australian Counselling Association or an accredited Registrant with the Psychotherapy and Counselling Federation of Australia.

· Developmental Educator – A person who is a Full Member of Developmental Educators Australia Inc.

· Dietitian – A person who is an Accredited Practising Dietitian with the Dietitians Australia.

· Exercise Physiologist – A person who is an Accredited exercise physiologist with Exercise and Sports Science Australia.

· Music Therapist – A person who is an Active “Registered Music Therapist” with the Australian Music Therapy Association.

· Occupational Therapist – A person who has a current Australian Health Practitioner Regulation Agency (AHPRA) Registration as an Occupational Therapist.

· Orthoptist ¬– A person who has current registration with the Australian Orthoptic Board.

· Physiotherapist ¬– A person who has a current AHPRA Registration as a Physiotherapist.

· Podiatrist – A person who has a current AHPRA Registration as a Podiatrist.

· Psychologist ¬¬– A person who has a current AHPRA Registration as a Psychologist.

· Rehabilitation Counsellor – A person who is member of the Australian Society of Rehabilitation Counsellors Inc. or equivalent.

· Social Worker – A person who is a member of the Australian Association of Social Workers.

· Speech Pathologist – A person who is a Certified Practising Speech Pathologist (CPSP) as approved by Speech Pathology Australia.

· Other Professional – A person who is not one of the types of professionals listed above but who the provider considers to be an appropriate professional to deliver therapeutic supports in line with the NDIS Quality and Safeguarding Commission’s requirements for the Therapeutic Supports Registration Group.

Question from facebook and response- Great comment Alex - might also be handy to identify the line items of concern rather than alarming everyone using Improved Daily Living ?

here are the line items of concern:

IDL Counselling

IDL Assessment/Recommendation/Training- other (provided Nutrition advice/information)- also referencing the Disability Related Health Supports Guidelines.

IDL Psychology-

Early Intervention Supports (under 7 Therapy)

IDL Social Work

IDL- Individual Living Skills- including Public Transport Training.

IDL- Training for Parents/Carers.

We are also exploring the risk to Jeder for the following (but have not done this yet as it may be appropriate that members are utilising these items if other avenues are not available or the Guidelines allow this):

IDL- Assist in Decision Making/Planning- using this line item in lieu of Support Coordination.

IDL- Other Therapy/Assessment/Recommendation- use of this line item in lieu of Behaviour Support.

The other thing we identified is that if we are to provide/offer these services, we need systems/processes in place to ensure we are providing them in line with the NDIS requirements and relevant professional standards/requirements- for example, if we are to provide Counselling, we need a Position Description and reissue of contracts, oversight of members who meet the requirements (i.e. Qualifications/Registration requirements), how any conflicts are managed, legal/ethical considerations (i.e. are notes available on Echidna regarding the Counselling session or is there a legal requirement to store elsewhere- and if so- where) etc.

From what i can see through the registration guide and the price guide we do not need registration for the other supports listed in the attached document, the line items and registration groups both explained. For the other 'therapy' supports it's a no brainer that we need registration.

@Drew Rogers thanks for adding to this- I will also answer this in the Facebook Post as well.

As an organisation, we do need to be registered for this category to make/process claims for Agency Managed Participants (which we are) but there are no additional requirements for registration (like there is for BIS, Psych, Counselling, Social Work, Speech Pathology etc). What we do need to be clear on is that our claims/services align to the requirements. A couple of examples from a COS perspective to think about:

• A COS is providing supports under the line-item Training for Parents/Carers (description- Training for carers in matters related to caring for a person with disability). The support delivered mirrors that of COS (i.e. no evidence of training for Parents/Carers provided/delivered)- the support is directly provided to the individual and no parents/carers. Is this ok to claim? How do we justify this if/when audited/questioned? What evidence of training do we provide? Is it better categorised under a different line item?

• A COS is providing supports under Individual Social Skills- incl. Public Transport (description- Individual training provided in the home for general life skills to increase independence).The support delivered mirrors that of a COS (i.e. no evidence of supports to develop individual social skills in the home). Is this ok to claim? How do we justify this if/when audited/questioned? What evidence of the skills development program do we provide? Is it better categorised under a different line item?

• A COS uses Assistance In Decision Making/Planning to provide ongoing COS to a participant that does not (description- Provision of time limited support to assist a person to develop and maintain daily budget, including assisting in planning purchases) or a COS uses this when they "run out of" COS Hours/Funding. Is this ok to claim? How do we justify this if/when audited (especially the time limited support)? What evidence do we provide?

@Jason Emmins

Hey Jason - I think 'run out of hours' is short form explanation that informs the major concern that support needs to continue with an obligation of duty to care to NOT leaving participants stranded with NO support - that would be the alternative? This concerns me that we ought consider that as the appropriate alternative.

The assist with Planning & Budgeting etc line item is under the same registration group (106) as CoS Level 2 - I am sure you are aware.

In my experience ANY use of this is time limited as it is intended to be heading to review, objective specific and goal orientated. I dont know anyone who has commenced support with this line item and also believe that ALL who do access at anytime - wish we didnt have to.

I have been supporting a participant with high complex needs, very complex and a myriad of therapists, incompetent provider (self delegated) Acute Care Qld Health assessments who avoids engagement at every turn. Its his first plan ever and setup as a 3 year plan with 10hrs of level 1 support coordination - read that again....... Six months later and an intense amount of work and liasing with a specialist support coordinator pro bono - TODAY confirmed a plan review date.......while the burnt out 73year old mother just doesn't understand why it took so long..........much of my work has been high of level engagement with a fractured team remains pro bono & some funds through IDL plan assist @$62.17........think I can justify this.

ALSO I have negotiated with 2 participants that this is a more effective affordable way to provide support for independent teams which in my mind is best use of funds and reasonable and necessary considering some of these tasks are not relevant to billing under CoS - discussed, negotiated, SoS in place with a limit and clear delineation with participant when we are having discussions of this nature as opposed to COS

@Kaeleen Hunter thanks- a few good points raised.

A few alternative thoughts- Echidna is great at tracking the "spending/utilisation rates" and if it's over 100% then I would suggest that a review should be discussed and implemented fairly quickly (either with the participant and/or NDIS). Is it negligent of us to over utilise plans (including Support Coordination)? Is this also not under our "duty of care" to monitor plan spends and make the appropriate enquires if we are over utilising them?

We can also say no to referrals in PRODA- with a reason being insufficient funding level- is this being done/used?

Yes, the Assist with Planning/Budgeting etc is under the same rego category as COS (as is Psychosocial Recovery Coaching). As indicated, we have not reviewed this just yet as we wanted to concentrate on the area that presented us most risk. If it is being utilised according to what it is intended, then there is no problems- all good. If its not, then we do need to explore this further.

Your examples are quite complex (particularly the 1st one). I would also make an argument that the work in self-managing teams is NOT a responsibility of a COS- this is a very different role and therefore should be funded separately to COS. In my mind the NDIS are very clear- a COS is not to provide this role. Are we blurring the boundaries and roles?

Warning. A few questions ...So as a provisional psychologist I've been billing under counselling (I have a PD for prov psych which I sent to someone in Jeder - can't remeber who ?? a year and a half ago - can resend), The above says · 'Counsellor – A person who is either a member of the Australian Counselling Association or an accredited Registrant with the Psychotherapy and Counselling Federation of Australia' . I'm registered with AHPRA not the counselling bodies and have an AHPRA approved supervisor.

From the NDIS site: 'AHP students or provisional psychologists on clinical placement can provide services to NDIS participants, provided they are under the supervision of a qualified AHP when delivering the services, and the participant has agreed that the student may deliver specific aspects of the support.

The service agreement between the provider and the participant should document this consent, and how the arrangement can result in additional flexibility (e.g. lower hourly rate or additional hours of service) for the participant.... a provisionally registered psychologist can charge at the rate applicable to an Allied Health Assistant Level 2 or as a counsellor.' Does this make it work for Jeder for us to continue to bill under Counselling with the appropriate consent etc?

Also, can you clarify this: As a reminder, the essential/mandatory documents include (no matter how a NDIS Plan is managed- this is a requirement as a Registered Provider):

• Service Agreements and Consents (for all positions).

• Schedule of Supports (for all positions).

• Risk Assessment (for all positions)

• Home Visit Checklist (for all positions)

• NDIS Plan/RFS (for COS).

• Implementation Plan (for COS).

• End of Plan Report/Progress Report (for all positions).

• Interim or Comprehensive BIS Plan (for BIS).

I can't see anything in the Practice Standards or Legislation that says these docs are mandatory. The NDIS site says that service agreements are mandatory only for SDA. They're recommended of course, as best practice. Do you mean that they're mandatory from an audit perspective? Where does the info that they're mandatory for registered providers come from? Not saying we shouldn't have them, but from a legal perspective we might not need to panic if we haven't had them to date?

Another question: Our service agreement is for all Jeder supports? And couldn't our risk assessment be applied to all supports? Just trying to avoid duplication if possible.

@Alexandria Brown thanks for your questions and transparency regarding this. I know that one of the Risk Jedi members will reach out to you to discuss specifics, but I will also respond here with some more clarity (I hope I have answered all your questions- if not reach out). Please keep the questions coming

• In terms of the PD- can you please forward the email you refer to me? We can then follow this up through the appropriate Jedi's and processes. From my understanding/perspective- this has not progressed through any internal process.

• In terms of the specifics for Counselling- yes this is some of the information. There is also information available about Provisional Psychologists which states:

  • Payment and claiming

    Students or provisional psychologists on clinical placement under supervision (usually an unpaid role) are not payable separately to their professional supervising practitioner.

    The supervisor can claim the relevant professional rate from the NDIS to create and supervise an appropriate program to be delivered by the student, with the participant’s consent. 

    As a paid unsupervised practitioner, a provisionally registered psychologist can charge at the rate applicable to an Allied Health Assistant Level 2 or as a counsellor. (Allied health practitioner students and provisional psychologists | NDIS)-

  • There are a few other factors we also need to consider in providing this service- including Position Descriptions/Contracts, Insurances for this specific area (I am also including Psychological Practice in this as well), confirming appropriate qualifications/registrations (and any conditions that may need to be considered etc), legal/ethical practices that need to be considered for these positions (i.e. recording of notes etc).

  • If you meet these requirements and we have all checks/balances in place, there should be no reason this service/support cannot continue. Without them it places you and us (as in Organisation) at significant risk (as we don't have any oversight/safeguards).

• Required Documents- these are contained throughout the NDIS Practice Standards (and indicators to meet the outcome-ndis-practice-standards-and-quality-indicatorsfinal1.docx (live.com) ). Without these documents- how do we justify and provide evidence we meet the standards? For example:

  • Provision of Supports-

    • Support Planning Outcome- each participant is actively involved in the development of their support plans. Support plans reflect participant needs, requirements, preferences, strengths and goals, and are regularly reviewed.

    • Service Agreements with Participants Outcome- Each Participant has a clear understanding of the support they have chosen and how they will be provided.

• Duplications- yes, it is always good to avoid duplications, but with each service there may be different requirements. For example- Risk Assessments, the BIS Team have developed their own Risk Assessment document specific for BIS, which is in addition to the COS one. If we are providing both BIS and COS, we may have two separate Risk Assessments as they are assessing and documenting different things (for example, a COS may identify the risk is Behaviours of Concern with a mitigation strategy being refer to BIS Plan; and a BIS Risk Assessment may specifically identify all the behaviours of concern and risks these present and mitigation strategies for this).

This document from the NDIA commission states that those IDL 'other supports' are only subject to a verification audit as i believe they are a verification only support so i'm curious as to what we would need for the audit that we already don't have?

https://www.ndiscommission.gov.au/providers/registered-ndis-providers/provider-obligations-and-requirements/understanding-what#paragraph-id-2724

I also want to acknowledge upfront there is a vast amount of information being discussed and shared here. This is great from my perspective but I am also conscious that for some people large amounts of information can be overwhelming. If you want to reach out, please do so.

I just want to let everyone know the Risk Jedlet for the IDL met today. We acknowledge there has not been any more communication on this, the FB thread or emails since last week. If you still have questions, we are happy to receive and respond to them.

The Jedlet are in the final stages of completing the last actions and will send another update out they have been actioned. We hope this will be mid/late next week.

Hey Jason - actually went to look for the meeting notes from today so I can be informed - can you provide a link or just direct me?

@Kaeleen Hunter howdi, we have kept the details private at this stage due to the sensitivity of the situation (i.e. involving individual members). Were you after something in specific?

@Jason Emmins - lets have a yarn soon eh - let me know when you are free :-)

@Kaeleen Hunter- yep- lets lock something in- does Friday sound ok for you? I should be relatively free from midday on Friday.

Hi everyone,

We hope you are going well and things are motoring along for you.

A review of the Improved Daily Living (IDL) was conducted in March/April this year (before things got really busy/hectic) and we realised we have not shared some of the feedback/learning regarding this piece of work. As we know, in late March the Risk Jedi was asked to do a review of the Improved Daily Living funding category due to concerns some members may be claiming under specific line items they are either not qualified or permissible under the NDIS guidelines.

There was acknowledgement some messages could have been delivered differently by the IDL Team and subsequent responses to this communication. It is safe to say that both sides felt vulnerable, attacked and offended. As a result, we now have important messages like this sent from Jeder Info.

Conversations were held with identified members and in most part these concerns were quickly and openly resolved (with either clarity for the member, exploring the requirements of those categories or recognition that some were one off errors). Several actions were identified to be worked on, including development of certain Position Description's and Supervision/Registration requirements for certain categories/roles/positions.

Some needs that were identified throughout the review included:

• A complete review of our Policy/Procedure and Handbooks- including developing an attachment that clearly identifies what categories could potentially be claimed under each position.

• Review of Echidna to see if we can ensure people do not claim for categories they cannot claim from (for example providing support coordination under therapy). This provides a level of safeguard for members and Jeder.

• Early Childhood Early Intervention (ECEI)- this was an area identified and included in the current scope of our next NDIS Audit.

• The need to be explicit about our claimable line items in induction and/or coaching.

• Explore if PRODA has various levels of permission so certain roles can only access/make bookings for certain things?

• Exploring ways how we can stop/minimise "knee jerk reactions" when issues/concerns regarding compliance are raised (eating the orange).

• How we all, as a flat organisation (self managed, non hierarchical) can promote a culture where we (members and the organisation) stop and think about what and how we are doing things (in terms of practice, process, the right thing)- this may provide opportunities for us to pause and adjust aspects of our systems/process/practices that need focus.

If there is any further feedback, please feel free to continue to add them here.

Thanks to the IDL Review Jedlet team for their prompt response and working through a difficult task.