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.