POLICY, PROCEDURE & PROCESS UNDER NDIS Incorporating NDIS Terms of Business Presented by Linda Hayes, Managing Director Corporate Synergies Australia Pty Ltd

Implementing NDIS - CSA Pty Ltd Workshop Objectives Review the NDIS process Introduce the NDIS Terms of Business Understand the effect on our business practices Discuss potential implications on service delivery Map our current Policies against HSQF frameworks Incorporate our procedures and processes Create your NDIS Readiness Checklist! Linda has over 25 years experience in business strategy and development across private, government and community sectors. More recently, Linda has been noted for her work in the Community sector, assisting organisations to transition business practices to those more sustainable under the emerging government funding models. Linda is a preferred business mentor and advisor to Bendigo Bank - Community Banking (NSW and QLD), professional contributor to NDS Qld, QCOSS and Better Boards Australasia, trainer with TDSA and CSDS, and in the past held advisor panel contracts with the Commonwealth Department of Social Services (Aged Care), and NSW Aboriginal Affairs.

The Emerging Environment A significant planned outcome of the National Disability Insurance Scheme (NDIS) is to develop a national competitive market for the provision of disability supports. This increasingly competitive environment requires all for-profit and not-for-profit service providers to be more effective and efficient across all areas of business practice – from client management to marketing. One of the key learnings from roll out sites to date is the amount resources (people, time and tools!!) required to transition our client’s from their current funding to individual service agreements and financial transactions. Our biggest fear was delay in payment from the NDIS. However, our own processes where information has to be manually duplicated across client data, rostering, payroll and accounts has created the most delays. Ineffective administration of essential business practices directly affects our viability under these new models. We need timely processes that maximise the outcomes for our clients, staff and cash flow.

QLD Registered Providers to Date… COAG Disability Reform Council Quarterly Report – 31 Dec 2016 https://www.ndis.gov.au/medias/documents/hdf/ha7/8800417972254/QLD-Dashboard.pdf

Implementing NDIS - CSA Pty Ltd The ndis process The tactics

The Transition Process

Transitioning to an NDIS Plan CSA © 2017 Implementing NDIS - CSA Pty Ltd Transitioning to an NDIS Plan Every Participant has a planning meeting with the Agency to discuss and formulate their NDIA Plan If funded under Disability Services, details will be transferred to the NDIA If funded under QCC or local community programs, they will need to apply for eligibility under NDIS The NDIA Officer assesses each person’s reasonable and necessary supports under CORE, CAPITAL and CAPACITY BUILDING with input from the Participant… and the plan is created. The Plan will be either Self Managed, Managed by the NDIA or Managed by a Plan Manager. Participants who’s plans are managed by the NDIA can ONLY receive supports from NDIS Registered Providers… self-managed and plan managers can use non-registered providers.

NDIA Act, rules and guidelines 31st March 2017 Implementing NDIS - CSA Pty Ltd NDIA Act, rules and guidelines The facts

3 levels of legislative practice 31st March 2017 Implementing NDIS - CSA Pty Ltd 3 levels of legislative practice National Disability Insurance Scheme Act 2013 National Disability Insurance Scheme (subtitle) Rules 2013 (pursuant to sec. 17 of Act) NDIA’s CEO “Operational Guidelines” (pursuant to a Rule under the Act) Forms, assessment tools, policies etc.

National Disability Insurance Scheme 31st March 2017 Implementing NDIS - CSA Pty Ltd National Disability Insurance Scheme NDIS Act 2013 (Cwth) – sec. 3 – Objects of the Act: (extracts only) Provide reasonable and necessary supports for participants in the NDIS launch (s.3(1)(d)) Enable people with disability to exercise choice and control in the pursuit of their goals and the planning and delivery of their supports (s.3(1)(e)) Adopting an insurance-based approach, informed by actuarial analysis, in the provision and funding of supports for people with disability (s.3(2)(b)) In giving effect to the objects of the Act, regard is to be had to … the need to ensure the financial sustainability of the NDIS (s.3(3)(b))

Cont… People with disability have the same right as other members of Australian society to be able to determine their own best interests, including the right to exercise choice and control, and to engage as equal partners in decisions that will affect their lives, to the full extent of their capacity. (s.4 (8)) Participant’s Plan must include any general or reasonable and necessary supports that will be provided or funded as part of the plan. Supports must provide value for money (s.34 ) Delegate documents statement of reasons for the decision (the letter that accompanies the provision of the plan) and provide a copy of the plan to the participant within 7 days.

Act - section 73… (2) The National Disability Insurance Scheme rules may make provision in connection with registered providers of supports, including by prescribing: (a) the consequences of registered providers of supports failing to comply with this Act, the regulations or the National Disability Insurance Scheme rules; and (b) requirements with which registered providers of supports must comply, including in relation to the following: (i) governance; (ii) business practice; (iii) accounting practice; and (c) the obligations of registered providers of supports in relation to the monitoring of compliance; and … (e) auditing requirements in relation to registered providers of supports.

Implementing NDIS - CSA Pty Ltd 31st March 2017 Implementing NDIS - CSA Pty Ltd NDIS Terms of business The rules

NDIS Terms of Business for Registered Support Providers Compliance (page 5) Registered Providers must comply with each of the following: The NDIS Act, Rules, all relevant guidelines and all policies issued by the NDIA Own Code of conduct, Code of Ethics or Service Charter Any Commonwealth, State or Territory laws applicable (Privacy Act, Australian Consumer Law, Quality Assurance, WH&S, Disability Services Act….) In Queensland, our quality and safeguarding arrangements are under HSQF.

NDIS Terms of Business for Registered Support Providers Service Agreements (page 6) Registered Providers should establish a written agreement with each Participant in the participant’s preferred form of communication the expected outcomes and the nature of services quality and price of supports to be provided and any agreed terms and conditions. the provider must ensure that the participant is regularly provided with details of services delivered Providers must also abide by relevant consumer laws regarding the provision of receipts and itemised bills. Service agreements must include a time frame for the notice of termination of services by the provider. Minimum notice period is 14 days.

NDIS Terms of Business for Registered Support Providers Conflicts of Interest (page 7) Registered Providers must ensure that they proactively manage perceived and actual conflicts of interest, including through the development and maintenance of organisational policies – which must specify how :- Ensure organisational values do not impede on choice and control Manage, document and report individual conflicts Ensure advice is transparent and promotes choice and control

NDIS Terms of Business for Registered Support Providers Payments & Pricing (page 8) Registered Providers must:- Adhere to the NDIA Price Guide Declare relevant prices to participants before delivering service including notice periods and cancellation terms Only make a payment request once support as been delivered. Submit a payment request within a reasonable time

Maintaining records (page 9) NDIS Terms of Business for Registered Support Providers Maintaining records (page 9) A Registered Provider must keep full and accurate accounts and financial records of the supports delivered to NDIS participants, along with records of service agreements. The accounts and financial records must be maintained on a regular basis and in such detail that the Agency is able to accurately ascertain the quantity, type and duration of support delivered. IF A REGISTERED PROVIDER MAKES A FRAUDULENT CLAIM, THE NDIA HAS THE RIGHT TO COMMENCE CRIMINAL AND/OR CIVIL PROCEDINGS.

NDIS Terms of Business for Registered Support Providers Complaints (page 10) A Registered Provider must have clear and accessible complaints handling and dispute resolution processes. Records must be maintained for at least five years or as required by law Providers are responsible for ensuring they remain compliant with all Commonwealth, State and Territory legislation.

Implementing NDIS – CSA Pty Ltd EXERCISE: SWOT Conduct a quick SWOT of your organisation, based on the key points of the Terms of Business. Areas of STRENGTH Needs Improvement

impacts on business practices Implementing NDIS - CSA Pty Ltd impacts on business practices The reality

+ changes in stakeholder reporting e.g. Members AGM, board, management, participants, Australian Charities and Not For Profits Commission (ACNC) Annual Report disclosure commentary – NDIS impact on participants, members, operations, management Financial Statements disclosure and commentary – material change in revenues, costs, assets, liabilities and benchmark ratios due to NDIS External audit disclosure – material change in funding sources from Govt. grants to participants’ service agreements revenues Provision for bad/doubtful debts Decision on recognising material “Work in Progress” (WIP) in financial statements.

+ impact on the General Ledger Within the National Standard Chart of Accounts General Ledger Account Codes for NDIS services revenues (NSCOA) Example - NDIS Item 09 011 - Assistance with self-care activities: weekday day e.g. 4-3500 General Ledger Organisational Activity Codes (using e.g. MYOB Category Code function) e.g. 106 Mobility assistance 108 Meals assistance General Ledger Client Codes (using e.g. MYOB Job Cost Code function) e.g. 407 Chris Brown

+ other considerations Providers now have to compete with all other providers that provide the same type of support as our own. All enquiries will need to be treated as potential new clients. Providers will need to be able to say what makes us the best – quality, price, approach, other??? Providers will need information on hand and a system in place as to how we manage this.

Administering the process CSA © 2017 Implementing NDIS - CSA Pty Ltd Administering the process INTEGRATED SYSTEMS FRAMEWORK Client Management Client enquiry Client intake Client data Client notes Client service agreements Conflict of Interest Complaints Records management Service Delivery NDIA Service Booking Service scheduling Staff selection Staff recruitment Staff rostering Staff timesheets Staff activities against NDIA items (fraudulent claims) Financial Management Payroll General Ledger Creditors/Debtors (bad debt) Job/Activity based costing (by client) Client invoicing Budgeting and forecasting Asset Management Claims and and Reporting Myplace Portal interfacing Payment requests (Price Guide) Client and stakeholder reporting Internal controls External audit Policies, Procedures, Practices and Processes Operations & Services Administrative and Management

Implementing NDIS - CSA Pty Ltd POLICY & PROCEDURE The

HSQF Standards Governance & Management Service Access & Delivery Implementing NDIS - CSA Pty Ltd HSQF Standards Governance & Management Governance Charter Policy 1 – CEO Delegated Authority Policy 2 – Strategic Management Policy 3 – Risk Management Policy 4 – Contracts & Financial Management Policy 5 – Information Management Policy 6 – Conflict of Interest Policy 7 – Business Practices Under NDIS Service Access & Delivery Policy 8 – Purpose of Service Policy 9 – Service Access and Agreements Policy 10 – Service Delivery Framework & Outcomes Policy 11 – Partnership & Collaborations Policy 12 – Management of Operations Policy 13 – Plan Management Policy 14 – Co-ordination of Supports Policy 15 – Stakeholder Reporting Individual Safety & Well-being Policy 16 – Management of Complaints and Appeals Policy 17 – WH&S Policy 18 – Discrimination, Harassment & Bullying Policy 19 – Termination of Services Sustainable Resource Management Policy 20 – Management of Human Resources Policy 21 – Management of Financial Resources Policy 22 – Management of Administrative Process Policy23 – Management of Capital Assets Policy 24 – Management of Information Technology

EXERCISE! Mapping our Procedures CSA© 2017 Implementing NDIS - CSA Pty Ltd EXERCISE! Mapping our Procedures In a group of 2-3… Choose one of the policies from the previous page… Create a list of Procedures and Work Instructions that should be included under that policy HINT!! Refer back to the Administrating the Process table for inspiration!

Implementing NDIS - CSA Pty Ltd Are you NDIS ready? The essentials

Implementing NDIS - CSA Pty Ltd

Implementing NDIS - CSA Pty Ltd Tips and Traps Know your services and service delivery model Know your true unit costs of service delivery and cash flow restrictions Be prepared to invest in time and resources for client transition Be prepared to invest in time and training for ALL staff Forecast required hours, skills, resources and hidden costs to the organisation Have all policies and procedures up to date and implemented Ensure finance systems are ready to go and report at an individual level Be ready to make regular payment requests to ensure optimum cash flow And remember… the best plans come from the best preparation – by everyone!!

Any questions? linda.csa@bigpond.com 0411 303 635

NDIS Service Categories (Plan Management) CORE Assistance with Daily Life Transport Consumables Assistance with Social & Community Participation CAPITAL Assistive Technology Vehicle modification Home modification CAPACITY Co-ordination of Supports Improved Living Arrangements Increased Social & Community Participation Finding and Keeping a Job Improved Relationships Improved Health & Wellbeing Improved Learning Improved Life Choices Improved Daily Living Skills NDIS Service Categories