Improved Daily Living Review
Hi everyone,
- FOR NDIS MEMBERS ONLY- URGENT ATTENTION NEEDED
The Risk Jedi was asked by the Coach’s POD to complete a review of the NDIS Capacity Building Improved Daily Living (IDL) category due to a concern that some members may be claiming under specific line items they are either not qualified to provide or not permissible under the NDIS Guidelines.
The Risk Jedi found several members are making claims against NDIS Categories (line items) they are either not qualified to claim against, they are not engaged in that role/position (i.e. don’t have a Position Description or Contract for that role), or providing services under IDL the NDIS does not permit. There are currently 28+ participants this may affect in terms of the services provided/delivered. The Risk Jedi identified this as an immediate significant risk requiring urgent/critical attention- we recognise this is an “Orange” area where we need to act swiftly.
Members of the Risk Jedi will make contact with each individual identified to seek clarity regarding the claims/services provided. These discussions are purely focussing on managing and addressing the risk to us as an organisation. The conversations could include:
Request to cease the support/service immediately, especially if significant concerns/issues/risks exist (i.e. individual is not registered to provide the specific service under NDIS or it’s a service that is not permissible under the NDIS Pricing Arrangements).
Clarification and evidence of any Qualifications and Professional Registrations (i.e. APHRA, AASW, Developmental Educators etc).
Invitation to assist in creating any Position Description that may be required.
Repayment/refund of any claims that may have been made without the appropriate Qualification/Registration, meeting the NDIS Guidelines/requirements for the category or reclassifying the line item to the correct one.
The Risk Jedi also requests that if you are currently claiming against categories outside of your position (i.e. for CoSSIE’s- Support Coordination, BIS- Improved Relationships) can you please review this urgently to ensure you are meeting the NDIS requirements (particularly around qualifications/registration requirements). If you have any doubts or concerns, please raise them with your coach and/or a member of the Risk Jedi.
We are currently preparing for our next NDIS Audit this year (towards the second half of the year) and need to ensure we are compliant against the NDIS Practice Standards, which includes claims/payments. If we are not, our entire Registration could be jeopardised (i.e. NDIS members are out of a job).
The NDIS also conducts periodical audits of claims and as an organisation we are required to submit our evidence (i.e. Service Agreements, Consents, Schedule of Supports, Case Note/s and invoice/claim reference) when its requested. We have experienced this a few times and generally we can respond quickly to these requests (as the information is available in Echidna).
It's also a timely reminder of the essential documents needed in Echidna to meet compliance/registration standards. You should have your Echidna Audit results from Ali and working through any areas of concern (the red). The Audit of IDL identified some/most essential/mandatory documents were not available/recorded in Echidna for the IDL Category. 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).
A post will also be made on Loomio and our Internal Facebook Page. Its important to us that we act upon this immediately.
If you have any questions or concerns, please raise them with your coach or a member of the Risk Jedi (Vic, Pennie, Harley or Jason).
You can also ask any questions on Loomio.
Drew Rogers Thu 30 Mar 2023 1:05AM
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?
Jason Emmins Thu 30 Mar 2023 1:29AM
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.
Jason Emmins Mon 3 Apr 2023 12:01PM
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.
Kaeleen Hunter Tue 4 Apr 2023 10:13AM
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?
Jason Emmins Tue 11 Apr 2023 6:16AM
@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?
Kaeleen Hunter Tue 11 Apr 2023 8:31AM
@Jason Emmins - lets have a yarn soon eh - let me know when you are free :-)
Jason Emmins Tue 11 Apr 2023 8:45AM
@Kaeleen Hunter- yep- lets lock something in- does Friday sound ok for you? I should be relatively free from midday on Friday.
Jason Emmins Wed 9 Aug 2023 9:54AM
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.
Jason Emmins · Thu 30 Mar 2023 12:40AM
@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).