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NDIS Position Statement

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Intelife Group Ltd (“Intelife”) has been a strong supporter of the National Disability Insurance Scheme (“NDIS”) since its inception and is committed to ensuring that the transition to the scheme in Western Australia (“WA”) is successful. 

A key tenet of NDIS is that of providing “Choice and Control” to people living with a disability. For choice and control to be effective it requires a healthy and diverse pool of service providers delivering high quality, innovative services, efficiently.   Intelife does not believe that the NDIS pricing model, in its current form, reflects the true cost of delivering the services required by people with a disability in WA. Accordingly, there is significant risk that NDIS will not deliver on the key tenet of “Choice and Control” for people with a disability in WA.

Customers Concerned

As Intelife modifies the delivery of its services to fit the NDIS operational model and seeks to assist our customers through the transition the impact on customers is becoming evident. It is concerning.

There are real impacts and genuine concern that the supports and associated funding is less under NDIS than under the historic state funded scheme. Issues that Intelife’s customers have to overcome include the following:

  • Planners inexperienced and with little understanding of disability;
  • Historic supports no longer funded;
  • Reduction in support hours due to disparity between duration of plans in different funding schemes (48 week plan spread over 52 weeks);
  • Significant percentage of new NDIS plans require review upon receipt – customers having to fight to get continuation of existing supports;
  • High need supports not understood resulting in diminution of supports and quality of life;
  • Transport either under-funded or not funded. Many customers cannot self-fund and public transport not viable leading to forced change to daily activities;
  • Lack of funding for respite for families.

Whist Intelife is putting significant effort to assist customers overcome the issues during the transition, issues such as under or non-funded supports cannot be fixed by a service provider. There is a clear need for closer working relationships between NDIS, providers and customers.

It is disappointing that many of the concerns customers and their families are experiencing in WA have been experienced in Eastern States over the last 3 years. In WA there has been time to plan for a better rollout of the scheme.


Ongoing Uncertainty

The National Disability Insurance Agency (“NDIA”), responsible for administering the NDIS, is taking significant efforts to communicate the detail and operation of the scheme. Providers are also dedicating significant time and resources in assisting customers understand the scheme. There still remains significant confusion by customers in relation to the operation of the scheme. 

The uncertainty is compounded by regular changes to the application and prices of NDIS. Intelife thanks the government for their response to the recent independent pricing review.  However, these ongoing changes assume providers and customers have the flexibility to react swiftly to change.  Educating staff and families, adjusting systems and procedures now on a regular basis has increased our administration costs substantially.

Intelife advocates to increase employment opportunities for people with a disability. We provide supported and customized employment service and have found it disappointing that nationally there is only one in fifty customers receiving employment in their plans.  There is insufficient detail on how supported employment will operate in NDIS resulting in confusion between providers, planners and families. Unless, remedied growth in employment participation will not occur.

The provision of respite services is not clearly understood by customers. Families and carers express strong concern over the uncertainty placing further strain on families during this period of change.

There is a need for clarity on the operation of the scheme in all respects as the lack of certainty confuses customers increasing stress and makes planning a business operation and/or strategy impossible.

Reduction in the level of Service Offered

For there to be a strong, diverse pool of service providers it is critical that the economics of service delivery support ongoing investment in the people, equipment and facilities necessary to ensure quality service delivery.  The pricing model used by NDIS is based on levels of labour utilization, training costs, supervisory levels and overhead and margin that are not always achievable. When combined with criteria for access to transport funding being unrepresentative of the distances travelled and costs involved in WA, the level of service that providers can offer to customers is lower than historically offered in WA.

WA differs from New South Wales and Victoria in that the public transport infrastructure and density of population and facilities is significantly lower and less developed. The cost of accessing the community is higher and the NDIS pricing model does not reflect that cost.

While Intelife has and continues to seek to improve the efficiency of delivery of its services and to develop a sustainable business model, it is increasingly difficult to offer the level of services its customers’ request and have traditionally accessed.  The lives of people with disability and their families are increasingly being impacted by the changes required to ensure sustainability of service delivery.

Market Failure

Whilst Intelife, like most of its peers, is committed to driving efficiency improvements and adjusting its business model to more closely align to the requirements of NDIS, some services are not sustainable. Intelife has undertaken detailed financial modelling of its business assuming it can achieve the labour utilization levels assumed in NDIS and even at those levels the delivery of Core Supports and Assistance with Social and Community Participation is cashflow negative once fully transitioned.

Unless there is a review of the pricing of core supports, transport and social and community participation there is a strong likelihood of market failure.  While Intelife is committed to the ongoing provision of its current services there is a risk that without revised pricing model criteria it may be forced to case delivery of services.

Award Remuneration 

The majority of support workers in the disability sector are employed under state and federal based awards.  These awards typically provide for annual escalation of wages and are prescriptive in the operation of key employment areas such as leave, rostering, allowances.  To date there is little evidence that pricing of supports in NDIS accommodates the costs of the award schemes. Intelife did welcome the inclusion of award escalation in the July 2018 review of support pricing.

Given that labour costs are approximately 70% of the cost of delivering a support service it is essential that there is a strong link between pricing of supports and the awards support workers are employed under. Additionally, given the projected growth in demand for disability support services there is a need for NDIA to engage with the sector and state and federal governments to develop an industrial agreement model that balances the need for wage escalation with the need to constrain continued escalation of support costs.

 Next Steps

Intelife asks that NDIA review the application of its pricing model for relevance in the context of WA, work more closely with providers and customers and clearly define the employment framework under NDIS. Whilst NDIA is providing communication publicly there is a need for increased direct engagement both with customers and service providers. Intelife remains committed to supporting its customers and their families whilst developing its business model and to working with NDIA in its goal of delivering the best service for people with a disability in WA.


Steve Edgar

Chief Executive Officer

Ph: 08 6169 1144