{"id":5116,"date":"2020-10-03T13:22:16","date_gmt":"2020-10-03T13:22:16","guid":{"rendered":"https:\/\/adacare.com.au\/?p=5116"},"modified":"2020-10-03T13:22:16","modified_gmt":"2020-10-03T13:22:16","slug":"ndia-released-plan-management-guide","status":"publish","type":"post","link":"https:\/\/project.hexondigital.com\/adacarenew\/ndia-released-plan-management-guide\/","title":{"rendered":"NDIA Released Plan Management Guide"},"content":{"rendered":"

The NDIA has just released the Guide to Plan Management<\/a><\/strong>. It is important to note that the new Plan Management Guide is not and is not intended to be a Plan Management Framework or Policy Setting, which the NDIA has been promising for the past three years. This is likely to frustrate and disappoint many Providers and the Broader Disability Supports Market. As such Providers must read the document as intended as a high-level information product only.<\/p>\n

Generally, the Guide has a fairly narrow or tight view of the service delivery model of Plan Management. The Plan Management market has in many cases has moved beyond the service structure offered within this Guide to facilitate greater flexibility and a more robust service for participants, as such many RPMPs might find this guide a bit lack luster<\/span>.<\/p>\n

\"Managing<\/h3>\n

BACKGROUND<\/h3>\n

Plan Management is a new industry that has been created as a direct result and advent of the Scheme.\u00a0There are over 1000 active Plan Managers across the country. As more participants elect to use this service, the industry has seen enormous growth. In the latest quarterly report, funding committed to Plan Management clocked in at around $237 million, representing a 29% increase in the market in just 3 months. Which, if you\u2019ve looked around at the Australian economy in the last few months, you\u2019d recognise as fairly unique growth.<\/p>\n

To date, a lack of guidance from the Agency has led to divergent understandings of what the service actually is. Looking at the required qualifications, the Commission only requires Plan Managers to be accountants or bookkeepers. It doesn\u2019t place any requirements or emphasis on Plan Managers being skilled or qualified in delivering person-centred support. This has led many providers to see the service as purely transactional. However, another school of thought sees it as the role of Plan Managers to unlock a plan\u2019s potential and empower people to live their best life through the freedom of financial expression. This is leading to some significant differences in the quality and type of support plan managers provide.<\/p>\n

REASONABLE AND NECESSARY BEFORE MAKING PAYMENT<\/h3>\n

One of the biggest controversies in Plan Management circles has been whether it is the responsibility of the Plan Manager to determine if a support is reasonable and necessary before making a payment. The Guide makes it quite clear that this is not <\/em>their responsibility.<\/p>\n

This answer makes complete sense. According to the NDIS Act, the only people able to determine reasonable and necessary supports are the delegates of the CEO.\u00a0 Even LACs need to get plans approved by the Agency.\u00a0 This is also a good reminder that reasonable and necessary pertains only to the allocation and inclusion of funding in a person’s plan at the planning stage, not what they spend it on.<\/p>\n

Hopefully, this will put an end to the practice of Plan Managers refusing to process payments they see as not meeting the \u2018reasonable and necessary\u2019 criteria.<\/p>\n

However, there is one catch. The Guide does say the Plan Managers have to ensure that the plan is being \u201cimplemented as intended.\u201d This is framed as a conversation about Payment Assurance & Integrity, rather than reasonable and necessary. The Agency even leaves Plan Managers liable to pick up the bill for any funds spent not \u201cin accordance with the plan\u201d, however the Guide does connect this sentence to the inappropriate use of government funds or cases of fraud.<\/p>\n

The ambiguity in these instructions makes it seem contradictory to the Guide\u2019s assertion that the Plan Manager’s role does not extend to deciding what supports a participant can access. Plan Managers cannot decide what support a participant can access, but they might have to foot the bill if they purchase the wrong one? Righto. Makes total sense.<\/p>\n

We really needed the Guide to provide more clarity on how Plan Managers ensure the appropriate expenditure of the plan, particularly when participants are free to claim reimbursements just like Self Managers.\u00a0That the plan should be spent \u201cas intended\u201d is hardly enough, given plans tend to be brief, system driven documents.<\/p>\n

The only real guidance Plan Managers can go on is Booklet 3- Using your NDIS Plan<\/a> which has seven questions participants need to ask themselves before purchasing a support on page 10. The Guide also refers to a Payment Assurance Program, but this is also very light on information. \u00a0It doesn’t tackle the questions of one-off payments or creative and innovative supports.<\/p>\n

So <\/em>in summary, this is what we know about plan managers:<\/p>\n

Plan Managers Do Not:<\/strong><\/p>\n