The NDIS funding reset starts today. Now what?

We made it. It’s 1 October and after months of announcements, amendments, guidance, questions and trying to work out exactly what these NDIS funding changes were going to look like in practice, they’re officially here.

And, just in time, we finally have the two Determinations that set out the rules. So… now what?

I spent yesterday working my way through the final Support Determination and High Support Needs Participants Determination. There is plenty of detail in both, but there are a few things I think OTs really need to understand from today.

First, a quick recap of the funding reset

For impacted Old Framework plans, the Support Determination confirms a 50% reduction to Assistance with Social, Economic and Community Participation and a 10% reduction to Improved Daily Living Skills.

Those percentages aren’t new. What we now have, however, is the final detail about exactly how they will be applied. And this is where it gets important.

Not everything within these categories will be reduced

It would be easy to look at a participant’s Social, Economic and Community Participation funding and think, “Okay, halve it.” But that isn’t necessarily what will happen.

The final Support Determination identifies a number of excluded subgroups. Funding attributed to these supports is excluded from the reduction.

Within Assistance with Social, Economic and Community Participation, the excluded subgroups are:

• Supports in Employment
• High Intensity Supports
• Intensive and Complex Behaviour Supports

Within Disability Related Health Supports, they are:

• Nursing supports
• Customised and Wearable Technology
• Hearing Services

The Determination then lists the specific supports that sit within each of these subgroups, and that detail matters. For example, the Disability Related Health Supports exclusion relates to specified nursing supports. It doesn’t mean everything we might broadly think of as a disability related health support is automatically protected.

So when we’re trying to understand what the funding reset might mean for an individual participant, we need to look beyond the broad funding category and understand what is actually funded within it.

This is particularly important for FCAs

For me, this is one of the most important practical implications for OTs.

When we’re completing an FCA, we need to be identifying when a participant has support needs that may meet the criteria for high intensity supports or intensive and complex behaviour supports, and importantly, we need to be evidencing those needs clearly.

If a participant requires high intensity supports, for example, that isn’t simply another detail to include somewhere in the report. Under the final Support Determination, funding attributed to that subgroup is excluded from the 50% reduction. The same applies to intensive and complex behaviour supports.

This doesn’t mean the OT decides which funding subgroup the NDIA ultimately applies. But our assessments do need to accurately describe the participant’s functional presentation, the support they require and the evidence that supports our recommendations. If these needs exist, they need to be visible in our assessment and reporting.

What if the reduction creates a support gap?

This is where the second instrument comes in. The High Support Needs Participants Determination sets out the safeguard pathway we’ve been hearing about over recent weeks.

To be considered a high support needs participant under this pathway, a participant must meet both eligibility criteria:

1. Their existing NDIS funding must cover support needs arising directly from their disability across a continuous 24-hour period, within Assistance with Daily Life, Home and Living and/or Assistance with Social, Economic and Community Participation.
2. Their combined funding across those groups must be at least $215,030 before the funding reset is applied.

Where an eligible participant’s funding is reduced and the remaining funding is insufficient to maintain NDIS supports covering their continuous 24-hour disability support needs, the Determination provides a mechanism for their plan to be varied.

In very simple terms, this is the safeguard intended to address the support gap created by the funding reset for this particular group of participants.

There is an important distinction here, though. Requiring support across 24 hours is not necessarily the same as having funded NDIS supports covering that continuous 24-hour period. That distinction is going to matter for participants whose support needs extend across 24 hours but whose current plans rely on informal supports to meet some of those needs.

So what should we be doing now?

I don’t think our starting point should be, “This participant has $X in Social, Economic and Community Participation, so they’re going to lose 50%.”

There is more to consider. What is actually funded within that category? Does the participant require high intensity supports or intensive and complex behaviour supports? Are any other excluded supports sitting within the affected funding? And if the reset does create a gap in their supports, do they meet the criteria for the High Support Needs pathway?

For OTs, I think this brings us back to something we talk about all the time: understand the participant’s actual support needs and evidence them well.

The legislation has landed and the funding reset is here. Now we need to work through what it actually means for each participant rather than assuming the headline percentages tell us the whole story.

How can you get on top of these changes in your OT practice?

If you’ve reached 1 October thinking, I understand the changes, but I’m still working out what I need to do differently in practice, there are a few ways I can help.

Join me for live training

In October, I am running New NDIS Era: OT Navigation Guide, a practical live workshop designed to help OTs understand the reforms and translate them into everyday practice.

We’ll spend the first part of the 3 hour session working through what has changed, including plan variations, reassessments and reviews, the NDIS Support Lists, Support Determinations, the High Support Needs pathway, functional capacity, reasonable and necessary criteria and what may differ across new plans, reassessments and renewals.

But understanding the reforms is only half of it.

In Part two, we’ll focus on strengthening the way we assess function, gather and triangulate evidence, make our clinical reasoning visible and write clear, targeted recommendations. We’ll also look at how to streamline reports so the evidence decision-makers actually need is easier to find.

I’m running the workshop next Wednesday and twice on Friday 16 October. Only the 8.30am session on Friday 16 October still has a few live spots available.

If you miss out on a live place, you can also add your details there to be notified when the self-paced version becomes available via the grey info box:

Want more ongoing support?

This week we’ve also made a major update to the Functional Capacity Assessment Report Template available to Inner Circle members in response to the changing NDIS reporting environment.

Some of the biggest changes include:

• Simplified functional assessment tables that focus on functional impact and evidence, rather than trying to include recommendations within every functional area
• Stronger recommendations that clearly identify what support is required, how much is required, why it is required and the expected functional benefit
• Greater emphasis on evidencing support hours and ratios, including a new recommended support schedule to map support needs across the day

These changes are all about helping OTs create a clearer evidence trail between the participant’s disability, functional impact, assistance required and the supports being recommended.

So if you’ve been on the fence about joining the Inner Circle, now is a very good time to take another look.