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

2. 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.

3. 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.

4. QLD Registered Providers to Date…
COAG Disability Reform Council Quarterly Report – 31 Dec 2016

5. Implementing NDIS - CSA Pty Ltd
The ndis process
The tactics

6. The Transition Process

7. Transitioning to an NDIS Plan
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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.

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

9. 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.

10. 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))

11. 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.

12. 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.

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

14. 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.

15. 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.

16. 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

17. 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

18. 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.

19. 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.

20. 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

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

22. + 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.

23. + impact on the General Ledger
Within the National Standard Chart of Accounts
General Ledger Account Codes for NDIS services revenues (NSCOA)
Example - NDIS Item Assistance with self-care activities: weekday day
e.g
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

24. + 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.

25. Administering the process
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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

26. Implementing NDIS - CSA Pty Ltd
POLICY & PROCEDURE
The

27. 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

28. EXERCISE! Mapping our Procedures
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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!

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

30. Implementing NDIS - CSA Pty Ltd

31. 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!!

32. Any questions?

33. 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