Supporting participants ineligible for SDA through Medium Term Accommodation

Is Medium Term Accommodation (MTA) available to participants who are not eligible for Specialist Disability Accommodation (SDA)? Can we support a person through MTA for a fixed term while their Individual Living Option (ILO) host arrangement is being finalised — specifically if they are ineligible for SDA?

Medium Term Accommodation (MTA) ensures participants have somewhere to live if they are waiting to move into a long-term home and their disability supports are not ready. To be eligible for Medium Term Accommodation, these three criteria must be met:

1. The participant has a long-term home that they will move into after medium-term accommodation.
2. They cannot move into their long-term home yet because their disability support is not ready.
3. They cannot stay in their current accommodation while they wait for their long-term home.

Generally, MTA needs to be approved and written into the participant's plan for the NDIA to fund it. If the above criteria are met, MTA for a fixed term can be put in place while the setup of an Individual Living Option (ILO) arrangement is being finalised. For example, if the ILO arrangement is confirmed but home modifications need to be completed, then MTA may be a possibility.

You can find more information on MTA in the guidelines on the NDIS webpage.

Claiming NDIS funds for Support Workers client specific training

We need clarification on whether we can claim support workers' time for attending individualised client-specific training from a client's NDIS funds.

The NDIS practice standards for High Intensity Supports require providers to ensure all staff working with clients who have high intensity support needs are competent and have attended specialised training specific to the client's needs. We have previously included support worker training time in service agreements and support budgets for training specific to the individual, as per the non-face-to-face supports guidance from the price guide:

The fee charged for non-face-to-face supports must reflect the needs of the participant in the context of the relevant support and be agreed upon with the participant.

Can we seek further clarification from NDS? We need assistance because the increased costs for providers to deliver services to clients requiring specialised training are making it financially unviable to continue providing these services.

This is a nuanced area. General training for workers is included in the hourly rate, however there is a limited ability for participant-specific training to be claimed. Ultimately, what can be charged depends on what the participant agrees to. They will need to understand the difference between the types of training. This agreement must be made by the participant or their nominee and should be included in a written service agreement. It must also be reasonable. Providers need to explain the difference between general training (which is usually covered in the hourly support rate) and training specific to a participant's needs. Examples might be training to carry out a diabetes management plan or enteral feeding.

We suggest that organisations document these two types of training clearly. This way, participants can see what is included in the hourly rate, what counts as additional individual training, and how often this training is needed — for example, every three or six months; or when new team members join. To ensure high-quality support for the participant, the documentation should also state the training requirements.

Providing sensitive documentation when participant is leaving a SIL service

What documentation are we required to provide to a Support Coordinator or a new support provider when a participant is leaving our SIL service? Some of the documentation is sensitive to our company, and we have invested a lot of time and expense in developing various procedures and care plans.

The participant and their family have also removed the support coordinator, and the new support coordinator has requested all incident reports and any other relevant documentation. We were in the process of recording different behaviours to apply for more supports that match the participant's needs.

Can you please advise what we are legally obliged to share with another provider? While I want to ensure continuity of support for the participant, I am hesitant to share sensitive information.

The NDIA outline their expectations for record keeping on the on the NDIS provider webpage for invoicing and record keeping. This includes keeping case notes, support logs, service agreements and rosters for group activities. Requirements vary depending on the support provided. The NDIA may request copies of this information. You can provide information directly to the participant but not to another agency or provider without the participant’s permission.

Victorian legislative changes

I understand that there is recent legislation changes that affect Victorian service providers, can you provide more information?

NDS are running a series of webinars to address the recent legislative changes to the Victorian Disability Act that affects Victorian service providers. Online sessions in June will cover restrictive practices, residential services, compulsory treatment, residential tenancy in disability accommodation (including enrolled SDA, SIL homes, and TAC, WorkCover and DSOA funded services), community visitors, information sharing and compliance requirements and offences.

For more information and to register, go to the NDS event page.

NDIS Plan indexation and extensions

I am contacting you regarding indexation and plan extensions.

It is my understanding that when the NDIA increases their rates, customers' plans are indexed in accordance with the Price Guide. However, it appears that when a customer has a plan extension, the NDIA simply doubles the dollar value without including any indexation.

For a SIL customer, it might look like this:

• Plan dates: 1 January 2023 to 31 December 2023; Plan funding: $104,000 ($2000 per week)

By 1 July 2023, the customer had used 50 per cent of their funding. The NDIA implements five per cent indexation. The NDIA applies five per cent indexation to the remaining $52,000:

• New plan funding: $106,600; New weekly SIL rate: $2100.

But if the customer gets a plan extension, the NDIA doubles the original plan value to $208,000, disregarding any previously applied indexation. This leaves us short of funds for the second year of the plan:

• Second year funding: $208,000 - $106,600 = $101,400 or $1950 per week.

Previously, this was not an issue, because these plan extensions often ended early. Now, with the PACE rollout, plan extensions are continuing for longer and customers are running out of funds.

Not only are participants running out of SIL funds, but many people have insufficient funding for external providers and participants need to stay home, which further affects SIL.

Questions: How should we proceed on this issue? And, am I misunderstanding how the plan extension and indexation are supposed to work?

In theory, pricing decisions (increases) made by the NDIA’s Annual Pricing Review (APR) should result in the indexation of a participant’s plan. For instance, plans were adjusted on 1 July 2023, when the APR considered increases in the Minimum Wage decision and the inclusion of paid family and domestic violence leave, among other factors. Whether indexation flows through with a plan extension is unclear and may depend on several factors, about which there is little transparency.

Ability Roundtable has suggested that for extended plans that have not included indexation, the price differential is expected, by the NDIA, to be absorbed by the under-utilisation of participant plans. This creates a scenario where, in service areas that typically do not have under-utilisation, such as Supported Independent Living (SIL), participants, to absorb the indexation in price, must forego hours of support that have been determined as reasonable and necessary.

Clearly, regardless of the size of the pricing decision increase, the increase should flow through to the participant’s plan to ensure continuity of funded supports, and any plan extension should be at the indexed rate.

At present, it is not possible to say how indexation has or has not been applied, because we have no formal advice from the Agency. They have also not clarified whether the example you have provided has been occurring across the board.

We will continue to seek clarification from the NDIA on this matter.

Complex bowel care

A client commencing with our organisation has a cecostomy button and requires bowel flushes twice a day. The high-intensity support descriptor guide, under complex bowel care, does not specifically say whether a support worker can complete these flushes or if they must be completed by a RN or nurse. Can anyone point me in the right direction to get clarification?

Support workers can perform flushes for a cecostomy button, but the qualifications required may vary. Generally, they need to be trained and supervised by a registered nurse or healthcare professional. The specific qualifications depend on the organisation’s policies and local regulations. It is essential to follow the instructions of the healthcare team to ensure safe and effective care.

Factsheets for High Intensity Daily Personal Activities and Skills Descriptors are available on the NDIS Quality and Safeguards Commission website in PDF and word formats

If you are seeking more information on cecostomy support, the Royal Children’s Hospital Melbourne have published guidelines on appendicostomies and caecostomies (pdf).