The NDIA has just released the Guide to Plan Management. It is important to note that the new Plan Management Guide is not and is not intended to be a Plan Management Framework or Policy Setting, which the NDIA has been promising for the past three years. This is likely to frustrate and disappoint many Providers and the Broader Disability Supports Market. As such Providers must read the document as intended as a high-level information product only.
Generally, the Guide has a fairly narrow or tight view of the service delivery model of Plan Management. The Plan Management market has in many cases has moved beyond the service structure offered within this Guide to facilitate greater flexibility and a more robust service for participants, as such many RPMPs might find this guide a bit lack luster.
BACKGROUND
Plan Management is a new industry that has been created as a direct result and advent of the Scheme. There are over 1000 active Plan Managers across the country. As more participants elect to use this service, the industry has seen enormous growth. In the latest quarterly report, funding committed to Plan Management clocked in at around $237 million, representing a 29% increase in the market in just 3 months. Which, if you’ve looked around at the Australian economy in the last few months, you’d recognise as fairly unique growth.
To date, a lack of guidance from the Agency has led to divergent understandings of what the service actually is. Looking at the required qualifications, the Commission only requires Plan Managers to be accountants or bookkeepers. It doesn’t place any requirements or emphasis on Plan Managers being skilled or qualified in delivering person-centred support. This has led many providers to see the service as purely transactional. However, another school of thought sees it as the role of Plan Managers to unlock a plan’s potential and empower people to live their best life through the freedom of financial expression. This is leading to some significant differences in the quality and type of support plan managers provide.
REASONABLE AND NECESSARY BEFORE MAKING PAYMENT
One of the biggest controversies in Plan Management circles has been whether it is the responsibility of the Plan Manager to determine if a support is reasonable and necessary before making a payment. The Guide makes it quite clear that this is not their responsibility.
This answer makes complete sense. According to the NDIS Act, the only people able to determine reasonable and necessary supports are the delegates of the CEO. Even LACs need to get plans approved by the Agency. This is also a good reminder that reasonable and necessary pertains only to the allocation and inclusion of funding in a person’s plan at the planning stage, not what they spend it on.
Hopefully, this will put an end to the practice of Plan Managers refusing to process payments they see as not meeting the ‘reasonable and necessary’ criteria.
However, there is one catch. The Guide does say the Plan Managers have to ensure that the plan is being “implemented as intended.” This is framed as a conversation about Payment Assurance & Integrity, rather than reasonable and necessary. The Agency even leaves Plan Managers liable to pick up the bill for any funds spent not “in accordance with the plan”, however the Guide does connect this sentence to the inappropriate use of government funds or cases of fraud.
The ambiguity in these instructions makes it seem contradictory to the Guide’s assertion that the Plan Manager’s role does not extend to deciding what supports a participant can access. Plan Managers cannot decide what support a participant can access, but they might have to foot the bill if they purchase the wrong one? Righto. Makes total sense.
We really needed the Guide to provide more clarity on how Plan Managers ensure the appropriate expenditure of the plan, particularly when participants are free to claim reimbursements just like Self Managers. That the plan should be spent “as intended” is hardly enough, given plans tend to be brief, system driven documents.
The only real guidance Plan Managers can go on is Booklet 3- Using your NDIS Plan which has seven questions participants need to ask themselves before purchasing a support on page 10. The Guide also refers to a Payment Assurance Program, but this is also very light on information. It doesn’t tackle the questions of one-off payments or creative and innovative supports.
So in summary, this is what we know about plan managers:
Plan Managers Do Not:
- determine what is reasonable and necessary
- decide what supports a person can access
They Do:
- ensure the plan is implemented as intended, within budget and in accordance with the plan
- enforce the price guide
- support people to understand their plan and the rules around how it can be spent
- not participate in fraud or the misuse of funds
PLAN MANAGEMENT SETUP FEE
Controversially, the Guide states that the Plan Management setup fee can only be claimed if there has been an initial meeting ‘to establish the financial arrangements between the participant and the Plan Manager.’ Plan Managers also need to keep a record of this meeting. Sensibly, the Guide allows for the meeting to be held face to face, over telephone or other online engagement.
This could substantially affect the revenue stream of some Plan Managers who are accustomed to claiming the establishment fee as part of the administrative sign-up process and NDIS portal set up, without having met with the participant. Plan Managers across the country vary drastically in the services they offer and their approach in this regard.
Hopefully, this initial meeting will enable Plan Managers to explain the services they provide to participants and result in greater plan utilisation. Unfortunately, we know that some Plan Managers are only processing their own invoices and the rest of the budgets remain unspent for the entire year. This small but important clarification should put an end to this practice.
Over 4 pages, the Guide details what should happen in this establishment meeting. It seems like the Agency are expecting a lot for only $232 and there’s not a lot of margin in the following $104 per month.
CHANGING PLAN MANAGERS
The Guide also confirms if a participant changes Plan Managers, then any invoices issued after the end date of the first Plan Manager are the responsibility of the new Plan Manager.
Whilst this might seem like common sense, the welcome clarification will stop participants being ping ponged between providers in the game of NMP (a.k.a. not my problem)! The number of wasted hours and distressing phone calls arguing over who is responsible for an invoice are officially over.
If the participant changes Plan Managers mid-plan, the establishment fee will not be available to the new Plan Manager. This is different to Core supports, where participants have the option of accessing a second establishment fee.
SCOPE OF PLAN MANAGEMENT ROLE
Right at the end of the Guide, in one of the smallest paragraphs in the document, we learn that a Plan Manager is not an LAC, ECEI Partner or a Support Coordinator. Surprise!
The role boundaries it does confirm is that a Plan Manager:
- Supports a person manage the funding of the supports in their plan; specifically relates to financial and plan managed supports.
- Does not undertake day-day administration management or maintenance of the entire plan.
- Is not responsible for connecting people to supports (funded, community or mainstream).
- Is not expected to maintain rosters or provide advocacy services.
- And it kind of ends there.
In reality, much more exploration is needed to examine the areas where these services do overlap. Some examples and professional case studies would have been particularly helpful here.
Most importantly, this Guide doesn’t address what happens when there is no Support Coordinator in place and the LAC is hard to reach. Who connects the participant to providers of supports, guides the service agreement and implements the plan? The Guide states the Plan Manager is not responsible for this, yet many Plan Managers have built their reputation on going above and beyond, filling in the gaps that make life harder for the participant.
PLAN MANAGERS TO ENFORCE PRICE CONTROLS
The Guide hammers home that Plan Managers must enforce the Price Guide no less than eight times! While this is a well established function of plan management, it was interesting to note this level of emphasis and begs the question, is this really what is most in the participant’s interests?
There seems to be a common belief in the sector that non-registered providers tend to price gouge. But what we see when we look at the actual claims made by people accessing Plan Management is that many pay under the Price Guide for their support. That’s right, despite the fear mongering, non-registered providers on the high street often provide better value for money. So if people are saving money in one part of the plan, why not allow them choose to pay more for another, similar to self managers? Wouldn’t easing price controls for Plan Managed participants give greater flexibility, choice and dignity?
According to the government’s response to the Tune Review, the Agency is looking to enforce the same safeguards on participants looking to Plan Manage as those who Self Manage. If this is the case, shouldn’t they be given the same rights as well? This would give people and families the ability to make real life decisions, at no extra cost to the Scheme. After all, you can’t blow out the cost of the Scheme by paying extra if you’re not over your annual budget.
PLAN MANAGEMENT PRICING
There’s no discussion of the price for Plan Management in the Guide itself, other than a link to the Price Guide. For me, this certainly calls to mind the Agency’s recent Price Review finding that “there is little evidence that the current price limits for Plan Management are inadequate”. For each participant, Plan Managers get $1485 a year (not including remote loadings), for delivering what can be a quite intensive support, particularly in the middle of a pandemic.
INSOLVENCY
Another notable absence from the Guide, is what will happen if a Plan Managers becomes insolvent, ceases trading or shuts down their Plan Management service stream.
THE FUTURE OF PLAN MANAGEMENT
This Guide could be expected to accelerate the reduction of Plan Management providers. According to Disability Intermediaries Australia’s Sector Report, 47 per cent of registered Plan Management who responded to their survey did not make a profit last year. And this was before the pandemic.
In response to this Guide, Plan Managers may need to review their service delivery models and some will need to change the way they do business. But more positively, we can hope that participants will become more empowered about what they expect from their Plan Manager. If the provider does not meet these expectations, we can assume people will vote the way they usually do, by taking their business elsewhere.
You can download the new NDIA Guide to Plan Management here.
Disability Intermediaries Australia have also created a point-by-point analysis of the Guide you can find here.
Here is summary from NDIS Plan Management Guide:
Why use a plan manager?
A plan manager can help you:
- increase your financial and plan management skills
- learn how to self-manage your plan
- pay providers
- increase your choice of providers
- get NDIS plan budget reports and greater budget oversight.
How can I have plan management?
At your planning meeting you can tell NDIS staff that you would like a plan manager to support you.
The NDIS will include funding in your plan to pay for your plan manager. This is separate from your other services and supports in your budget.
If you are mid-plan and want to change, contact us on 1800 800 110 to discuss how you can include plan management in your plan.
How do I find and connect with a plan manager?
You can find and connect with a plan manager through:
- your Local Area Coordinator, Early Childhood Partner or support coordinator
- the Provider Finder tool on the NDIS myplace participant portal
- your friends and famil
- other online resources and websites.
After I have connected with a plan manager, what do I do?
Once you have connected with a plan manager, you should create a service agreement.
A service agreement outlines:
- the services to be provided
- how these services will be provided
- how long they will be your plan manager.
How do I change plan managers?
You can choose your plan manager. You can also change your plan manager during your plan.
If you wish to change, you will need to tell your plan manager. They will provide you with information about your plan and help you to change.
Complaints and feedback
If you have a complaint with the service of your plan manager, start by having a discussion with your plan manager. They may be able to resolve the issue.
If you are not happy with that outcome or you do not want to discuss the matter with your plan manager, you may lodge a complaint with the NDIS Commission .
Frequently asked questions
Should a plan manager advise you when NDIS funds are low?
Yes, a plan manager should provide regular reports and statements to you directly.
When a plan manager has identified overspend or underspend, the plan manager should advise you as soon as possible, regardless of reporting frequency.
Should a plan manager advise a provider when NDIS funds are low?
No, a plan manager should contact you directly.
This will allow you to contact your provider, support coordination provider or partner in the community, to discuss current service delivery arrangements and make any required amendments.
How long should it take a plan manager to pay a provider?
A plan manager should arrange for prompt payment to a provider or prompt reimbursement to you.
The NDIA expects a plan manager to validate an invoice and submit a payment request to the NDIA within five business days of receipt.
Upon receiving payment from the NDIS, the NDIA expects payment or reimbursement to occur within two business days.
Should my plan manager claim all plan funds at the start of my plan?
No, a plan manager can only submit claims for supports and services after they have been provided.
Once an invoice or receipt has been issued and sent to a plan manager, they will make a claim for that amount from the NDIS.
All plan funds remain with the NDIS until a plan manager submits a claim for that amount.
Should a plan manager help to determine whether supports or services are ‘reasonable and necessary’?
No, the role of a plan manager is not to determine whether the supports or services purchased are ‘reasonable and necessary’.
Your plan will have funds approved for reasonable and necessary supports at the planning stage.
The role of the plan manager is to ensure your plan is implemented as intended. This includes ensuring funds are being spent in accordance with your plan.
Why do plan managers operate differently to each other? Why isn’t there a set of standards to follow?
Plan managers are expected to follow payments and price controls established by the NDIA.
Plan managers are also expected to follow the service expectations set out in the NDIS Guide to Plan Management. The guide does not prescribe what services a plan manager should provide, so the services offered may vary.
Who is responsible if a provider submits an invoice to a plan manager and there are not enough funds available?
Plan managers should work with you to reduce any potential for plan overspend. This will involve regular reporting of plan managed budgets as outlined in the NDIS Guide to Plan Management.
Your plan manager should discuss with you effective and efficient ways to utilise approved funds.
If your NDIS plan funds are being spent faster than anticipated and there is a risk that funds will be exhausted before your next review, your plan manager should discuss this with you.
If you require additional funding (for example, due to a change in circumstances), contact us to discuss your options.
Who is liable to repay any amounts that are not spent in accordance with your plan?
Inappropriate use of government funds or fraud are serious matters.
A plan manager may be liable to repay any amounts which have not be spent in accordance with your plan.
For more information see the Provider Payment Assurance Program.
Why can’t a provider be advised of the allocated plan management funds in my plan?
Providers should work closely with you to develop a service agreement. The service agreement should outline how and when the supports will be delivered.
Your plan manager should report regularly to you on your plan spending. This reporting will help you to keep providers advised.
If I change plan manager, who is responsible for paying my ‘old’ invoices?
If you change your plan manager, the new plan manager becomes responsible for the ongoing management of your plan.
This includes, to process payments on your behalf, irrespective of the date the services were rendered or the invoice date. This is to ensure that any late invoices issued by a provider from earlier in the plan period are able to be paid.
The NDIA expects payments of this kind will only be required in special circumstances.
What is the difference between a plan manager and a support coordinator and a partner in the community?
A plan manager will pay providers for supports delivered. A plan manager will help you monitor your funds, and provide financial reporting.
A support coordinator will support you to understand and implement supports included in your plan. He/she will link you to providers and other community and government services. He/she will also support you to build skills and direction.
An NDIS Partner in the Community delivering Local Area Coordination or Early Childhood Early Intervention Services may provide plan implementation and monitoring support to you. Partner organizations are appointed by the NDIA to help you understand the NDIS, and find providers of support suited to your needs.
Can I pay my providers more than the limits set in the NDIS price guide?
No. If you are using a Plan Manager, providers cannot charge more than the price limits outlined in the NDIS Price Guide and Support Catalogue.
What other costs can plan managers charge?
From 1 July 2020, plan managers can claim for supports not delivered in person. This includes travel costs incurred to deliver supports.
More information is in the Price Guide and Support Catalogue 2020–21.