Credability Systems Submission to NDIS Review

The Role of Intermediaries in Navigating the NDIS

It is clear from the NDIS Review- ‘What we have heard’- Report that the committee is aware of the confusion and crossover of roles between the various intermediaries within the current NDIS structure. While the term ‘intermediaries’ covers a wide range of roles, this submission will primarily (but not solely) focus on the role of Plan Managers as the largest plan funding management type (60%), and representing Credability Systems’ direct customers. Credability Systems supports Plan Management as a sustainable method of oversight and accountability for a large portion of scheme funding.

Current Plan Management Landscape

There are contextual factors that must be considered and acknowledged to fully understand the complexities faced by Plan Managers in this industry.

• Plan Managers are required to fully understand NDIS finances, systems, and complex processes. With any changes to pricing or processes, the need to update their knowledge costs both time and money to educate staff and continue to maintain their expertise. 
• Many Plan Managers are already managing two computer systems as the NDIA tests and transitions to PACE. Throughout the next 18 months, all Plan Managers will be expected to operate across both systems. With this transition comes additional unpaid training, teething problems and administration time, as well as changes to business processes. In addition, there may also be additional support required for Participants and their Carers to assist in navigating the changes.
• The flat fee reimbursement model that Plan Managers receive does not accommodate for the changes in workload due to the size of plan budgets or complexity of Participant needs. There has also been no fee increase in over 4 years despite rising inflation and increases to other supports such as SCHADS award.
• The compliance team expects audit work to be completed under a strict time frame, which costs an organisation additional unplanned time and money. There is no additional remuneration and often little to no feedback or response once this work is completed. Short turnarounds cause additional workload and directly impact the level of services provided to participants.
• The increasing consolidation of Plan Management agencies by larger companies, including insurance companies, can have a negative effect on Participant experience. There is increasing discourse in Social Media groups around a perceived reduction in service levels provided and extended payment delays attributed to these large conglomerate agencies, resulting in a need to protect the service level requirements for the Plan Management sector. 

One Plan Manager warns that “larger players with the capacity and experience in other payment sectors (e.g. Medicare, POS, consumer finance) and the investment funds available will dominate the sector and cater for the ‘standard’ PM participant and service providers who can invoice correctly. This will leave the non standard/complex participants to the smaller players with consequently more work required for a diminishing revenue return.”

• Additionally, the profitability of Plan Management Agencies is still far too low to be considered acceptable.  This is resulting in significant churn of Plan Management Agencies effectively exiting the industry
• Unclear roles and unfunded supports, such as Support Coordination, are contributing to additional unpaid services being taken on by some Plan Managers as they fill gaps.
• The total number of Plan Managers has remained almost stagnant for the past 7 quarters (see below chart). In the past two years, the average number of Participants to Plan Managers has grown from 197 in Q4 2021 to 250 in Q4 2023. While the increase in efficiencies is to be commended, there will come a point where service levels decrease if the number of Plan Managers does not continue to grow.

Source: Q4 2022-23 Quarterly Report

Recommendations

Credability Systems has received insights from Plan Manager interactions and through Social Media discussions and has identified 5 recommendations for consideration by the NDIS Review. These recommendations include a greater focus on clear plan management education, stimulating the Plan Manager role, clarification of key roles, definitions, and processes, an emphasis on training amongst all intermediaries, and leveraging big data and the insights it can provide.

Recommendation #1: Plan Management Education

There is a common rhetoric around Plan Managers acting as gatekeepers or questioning invoices that is causing frustration for Participants, their Carers, Providers and Support Coordinators. Clearer information should be made available as to what guidelines Plan Managers are operating within as part of their role, and why they sometimes require substantiation or additional information. The information currently available on the NDIS website does not clearly compare between options. Some providers display these differences in tables that make it easy to compare, however the information can be subjective and misinformation is spread. 

There are clearly intended roles and responsibilities for intermediaries outlined by the NDIA. In reality, various situations can occur that leave Participants without support to understand their funding or implement their plan. In some cases, Plan Managers provide this information and support as an unpaid service outside of their intended role. As part of the determination of roles and responsibilities of intermediaries, the NDIS Review panel must consider these scenarios and plan to ensure Participants always have an avenue for support. 

Recommendation #2: Plan Management Market

Reinvigorate Market

The number of Plan Managers is stagnating, despite the increase in Participants choosing Plan Management. The combination of issues outlined for context above, namely the constantly changing environment and systems without increases in reimbursement, is affecting the appeal of the role. “Honestly for the pittance we receive for our jobs, I do often wonder if it’s worth it” The NDIS Review panel must ensure they protect the sustainability of this vital role for such a large portion of Participants. 

PACE Transition

Credability Systems has witnessed our customers as they transition or plan to transition to the new PACE system. There is considerable time required to train directors and staff and amend business processes, let alone the additional support required to assist other stakeholders. A one-off remuneration for system transition would alleviate some of the financial burden associated with this lengthy and time-consuming process for Plan Management Agencies.

Recommendation #3: Clarification of Liability and Risk

Plan Managers are duly responsible for ensuring financial management on behalf of Participants. However, there are contradictions between the level of responsibility and the liability they face. It is clearly outlined that ‘the role of a plan manager does not extend to determining whether supports or services which have been purchased are ‘reasonable and necessary’.’ However, there are instances where supports are ambiguous and Plan Managers are requiring confirmation from NDIA that they are ‘reasonable and necessary’ before processing to reduce their liability risk. This occasionally leads to complaints of ‘gatekeeping’ and/or a change of Plan Manager. A Plan Manager recently commented on social media ``We call the agency and get a ref no. No push backs and time wasting this way.” This is causing double-handling and frustration from all stakeholders, not to mention the increased activity through the call centre. This could be addressed through increased education and training, and more clarity around funded supports.

Recommendation #4: Standardised Training

There is minimal training provided by NDIA that directly relates to the Plan Management role outside of pricing and payment controls, and service expectations. Despite some independent organisations or consultants offering introductions to Plan Management, the role is primarily learnt on the job. The result is often varying levels of service and understanding of funded supports, leading to confusion. With such a large portion of Participants choosing Plan Management, a simple standardised induction training provided by the NDIA would be beneficial in setting a baseline of service and knowledge.

Recommendation #5: Leverage Data Insights

The NDIS Review panel has highlighted a lack of visibility in some areas of provider data. This information is essential to assessing markets and pricing, and identifying fraudulent activity. Some of this data is currently being captured by software providers, but its use is hindered by data privacy. By allowing approved NDIA aggregators to leverage the extensive data collected, additional safeguards and alerts could be implemented to support Plan Managers in identifying potential risks or fraudulent activity. 

Summary

Credability Systems supports the need for an NDIS Review to revitalise and sustain the scheme for future generations. The recommendations set out in this submission should be considered in conjunction with the other areas of improvement identified, ensuring Plan Management remains a viable and sustainable role of financial oversight within the NDIS.

About Credability Systems

Who we are:

Credability Systems is a fully licensed FinTech and SaaS provider focussed on improving the NDIS claims and payments experience for all stakeholders. Our team combines extensive technical, industry, and lived experience to create unique and innovative products, purpose-built for the NDIS.

What we do:

We create cutting-edge technologies that work together to automate manual tasks, and improve the speed of claims responses, payments and goods dispatch for essential goods and services. We build our own platforms in-house to the highest standard to ensure they’re easy to use, maintain and support, and are ready to develop further to address changing needs as the NDIS evolves. 

Who we serve:

Our core clients are NDIS Plan Managers. We have designed our Plan Management Software, Planability, specifically to streamline and automate daily administration tasks and improve efficiencies in business processes. This helps our Plan Managers spend more time in actually supporting their Participants and Carers.

Our Credentials:

We work with a large number of Plan Management Agencies as our core customers, with over $1B in claims processed annually through our Plan Management Software, Planability. We facilitate interactions between Plan Managers and Service Providers, Support Coordinators, Carers, and Participants, amounting to over 100,000 associated NDIS parties through which we receive insights around pain points and positives of the scheme.

We have received ISO27001:2013 certification and Aggregator status with NDIA. As a digital partner, we are proud to have been one of the first companies utilising the PACE API’s, future-proofing our platform for the upcoming ICT system transition.

Australian Financial Services License (AFSL 467065)  | Australian Credit License (ACL 390330)