MyCareSpace

As a social enterprise that has connected more than 50,000 NDIS participants with NDIS supports and services, MyCareSpace is in a strong position to reflect on key recommendations, following last year’s NDIS Review.

In particular, the proposed recommendation that would see all providers registered with the NDIS is one that has created passionate debate among both of the communities we serve. Participants have strong feelings about what this will mean for them and many providers are anxious about the impact this will have on their business.

The new model proposed is based around a Provider Risk Framework to assess which supports and services may need more oversight and regulation than others.

No doubt, improvements in the sector are essential to ensure people with disability and their families receive best quality services and supports, and registration and compliance will play an important role in achieving this. The trick is developing a model that improves the quality of services and trustworthiness in the sector, without negatively impacting the number of providers in the market.  In some regional and rural areas there is a chronic under-supply and for specific services like Allied Health, the demand exceeds supply in almost every location.  

MyCareSpace recently provided a submission to the NDIS Provider and Worker Registration Taskforce outlining important considerations on the proposed new model.

Our submission represents not only our own perspectives, but also the voice of both participants and many providers who have been grappling to understand the impact of the new recommendation on their daily lives.

Here’s what you need to know.

Enhancing Provider Accountability and Quality

The introduction of mandatory registration for all NDIS providers aims to enhance the accountability and quality of services provided to people with disabilities. Historically, the low barriers to entry for NDIS providers allowed a broad range of providers to participate in the scheme, however this also opened doors to unscrupulous operators and underqualified workers.

The proposed model features a tiered registration system linked to the service's risk and complexity, which seeks to maintain a diverse provider base while ensuring that higher-risk services meet more stringent requirements.

Cost Considerations and Support for Smaller Providers

One of the critical points MyCareSpace raised in its submission, concerns the cost associated with registration. For many small providers and sole traders, the financial and administrative burdens of registration is daunting. The proposed model has focused on the requirements of registration but has not addressed the big issue of cost for providers, especially for low risk providers.  MyCareSpace has proposed the costs associated with the registration process and the audit should be proportionate to the provider's scale and service complexity, potentially easing the burden for smaller providers and encouraging their continued participation in the scheme.

Strengthening Worker Screening and Training

Another key aspect of the proposed changes is the emphasis on worker screening and training. MyCareSpace supports the proposed introduction of a national, portable worker screening check as critical in safeguarding participants. This would ensure all workers in direct contact with participants have been adequately vetted. Furthermore, it is our recommendation that mandating basic online training for workers would help them to understand their obligations and ultimately enhance service quality.

MyCareSpace surveyed 63 providers to further inform our submission, of which 29% are registered, 54% unregistered and 16% waiting for registration approval, including sole traders and providers with up to 100 employees. 

Overwhelmingly, 80% of respondents agreed that every person providing participant support should have a NDIS Worker Screening Check, with the remainder stating that a police check, working with children check, or recognised qualification, such as TAFE certificate, would suffice. 

In addition, 76% say NDIS Worker Screening will help decrease risk and better protect participants receiving NDIS services, while almost 74% of respondents agree support worker training is important. 

Regulatory Oversight and Compliance

Enhanced regulatory oversight is a foundation of the proposed registration model. MyCareSpace advocates for regular compliance monitoring and a clear process for addressing non-compliance, including financial penalties. This approach aims to deter unethical behaviour and ensure providers adhere to high standards of service delivery. Onsite visits and audits would verify the accuracy of reported information, further strengthening the system's integrity.

Compliance monitoring will be essential to make this registration model successful. Providers need to believe that unethical actions will result in financial consequences, such as revenue clawbacks or punitive fines for directors and business owners. The introduction of more “boots on the ground” staff to perform unscheduled onsite visits and validate information from desktop audits and self-assessments, would be welcome.

Consulting with and employing people with disability (PWD) to provide input on provider registration, auditing and compliance monitoring would be valuable. This would ensure PWD perspectives and needs are prioritised, ensuring a more inclusive and effective oversight mechanism. These changes will also give insurers greater transparency and access to standardised regulations, which can become a minimum requirement for accessing insurance, indirectly enforcing compliance.

Promoting Participant Rights and Choices

The proposed model aims to uphold the rights of people with disabilities by setting a minimum standard of care that all providers must meet. This approach is designed to level the playing field, enabling NDIS participants to make informed choices about their care based on transparent and reliable information about providers.

Currently, it is challenging for participants to validate a provider’s skill level. A model that helps participants understand the experience and expertise of their providers based on a registration category would be highly beneficial. This transparency extends to key stakeholders, such as insurers, who currently have limited information about provider skill levels since training and expertise are not prerequisites under the existing system.

Creating more awareness among people with disability about what makes a good provider is essential. These individuals are entitled to know and understand what their consumer rights are and what red flags to watch for when engaging a provider. This knowledge will not only empower people with disabilities to make better-informed decisions but it will enable them to advocate for their rights more effectively.

Supported Independent Living (SIL)

The proposed advanced registration for all high-risk supports is a welcome change, particularly for daily living supports in closed settings, particularly in the home. Supported Independent Living (SIL) is among the highest risk settings within the NDIS, yet currently, any provider can offer this service regardless of their experience, qualifications, or training.

MyCareSpace receives hundreds of enquiries from "SIL Providers" wanting to join our platform and connect with NDIS participants who have SIL funding. Upon extensive screening, we find that many of these providers lack prior experience in delivering this high-risk support. Despite this, many believe they are well-equipped to sign on their first participants, often driven by the economic value of SIL.

Implementing advanced registration for high-risk supports will ensure that only qualified and experienced providers can offer such services, safeguarding participants and maintaining high standards of care - comparable to other environments where work is undertaken with the more vulnerable.

Challenges and Recommendations

Despite the potential benefits, the transition to a mandatory registration system presents challenges. Providers expressed concerns about the impact on small businesses and those operating in rural and remote areas, where service options are already limited. MyCareSpace suggests that the taskforce consider exemptions or modified requirements for these providers to prevent a reduction in available services.

Moreover, the feedback from providers underscores the need for a balanced approach that protects participants without unduly burdening providers. The administrative overhead, particularly for small providers, and the cost implications of registration and compliance is a major concern requiring careful consideration to avoid unintended consequences, such as reduced provider diversity and choice for participants.

Another important aspect to address is enhancing the business acumen of providers. While this alone may not seem critical, having a strong foundation in basic risk management and risk mitigation should be a prerequisite for starting an NDIS business. This ensures providers are well-equipped to deliver high-quality, safe services to participants.

Ultimately, the proposed registration requirements for NDIS providers are a step toward a more standardised and secure system that prioritises the safety and rights of participants. While this move is welcomed by many, including MyCareSpace, it is crucial that the implementation of these changes considers the diverse needs and capacities of all involved. By fostering a collaborative approach and refining the proposed model based on stakeholder feedback, the NDIS can ensure that the new registration framework benefits providers, workers and participants alike.