It’s been a long time coming, and finally the NDIA have released their Guide to Plan Management. Since NDIS Plan Management services were created, there has been a lack of extensive information and varied interpretations of their roles. This has created a lot of confusion around how much power a plan manager should have when it comes to managing a participant's NDIS plan funding.
This has led to the quality of services provided by plan managers to differ greatly from one plan management provider (PMP) to another. As of June 2019, the NDIS report showed that the proportion of participants who have a plan manager has increased from 13% to 34%. In April 2020, the Australian Disability Intermediaries released a Sector Report showing that 74% of Plan Management Respondents agreed or strongly agreed that the policy environment is unclear. So, it is certainly a relief that the latest guide provided some further insight on these matters.
The NDIA released the guide with the intention of informing participants, providers and the wider community around a large number of those grey areas when it comes to Plan Management services, so here’s the lowdown on what the guide covers:
- What to expect from Plan Management?
- How to access Plan Management?
- What are a plan management provider's roles, responsibilities and activities?
- How does a plan manager support a participant to get the most out of their plan?
- What other areas fall into the overall scope of a plan manager?
Download a copy of the NDIA Guide to Plan Management Here
What we already knew about PMPs
- All PMPs must be registered as per the NDIS Act
- NDIS participants who are plan managed can access services and support from both non-registered and registered providers, as long as they adhere to the NDIS price guide.
- PMPs should communicate with participants in the way that best suits them
- A participant can chose to have part or all of their plan managed by a PMP
- The funding for these services are allocated to a participants plan as separate funding
There are two types of services a plan manager can offer:
- Financial administration
- Capacity building & training
Here is what’s new?
WHAT TO EXPECT FROM A PLAN MANAGER
Section Three of the guide focuses on the importance of the plan manager GUIDING and ASSISTING the participant and working together. It is NOT within a Plan managers scope to deny a participant from using a service, or to determine whether the supports or services purchased are ‘reasonable and necessary’.
Funds are approved to be reasonable and necessary at the planning stage, and the plan manager should ensure the funds are spent in accordance with a participants plan, and as intended upon implementation.
It has also been made clear that if funds are used inappropriately or fraudulently, this is a serious matter and the plan manager would be liable to repay any amounts which have not been spent in accordance with a participant's plan. It is clear that moving forward this could create a point of contention. If participants are still able to claim reimbursements for services, there is a limit to the control the plan manager has over this, however they may still be required to cover these funds.
In many ways, this highlights the importance of the establishment meeting, and ongoing assistance where the plan manager must clearly outline how and where the plan's funding is intended to be used.
Duties outside of scope of Plan Management
In an attempt to clarify the roles of a Plan Manager, the guide also explains what is outside the scope of duties of a Plan Manager. NDIA resolves that a plan manager is not a Local Area Coordinator, Support Coordinator or Early Childhood Early Intervention (ECEI) partner. This means they while they are responsible all financial tasks, a plan manager will not:
- Connect, organise or schedule a participants services with other providers
- Manage schedule or appointments
- Provide disability related advocacy services
- Decide what supports a participant can or cannot access, or in other words determine what is reasonable and necessary funding under a participants plan.
The establishment process has been formalised, and whilst the majority of plan managers already comply with these requirements, it appears that there will be a shift in how some PMPs conduct this activity.
The meetings must be face to face, via telephone or other online engagement, and providers must keep record of these meetings and include this process in the Service Agreement.
The aim of the establishment meeting is to:
- Explain the scope of each parties roles and responsibilities
- Understand the participant’s supports and goals
- Ensure they communicate using a participants preferred communication method
- Assist with processing payment requests
- Explain the PMPs schedule of fees
Note that existing plan managers are not required to re-do existing service agreements, if this was not previously included, but this process must be completed in future engagements.
The service agreement issued following the establishment meeting will help to make sure a “participant and plan management provider have the same expectations of what support will be delivered and how it will be delivered.”
What if plan managers are changed mid-plan?
Surprisingly, if a participant chooses to change Plan Managers mid plan, the initial establishment fee is not available to new Plan Managers. However no doubt , the new Plan Manager will still be required to establish the goals, outcomes and activities intended for the participants plan funding.
PRINCIPLES OF PLAN MANAGEMENT
The specific activities expected of a plan manager are outlined on pages 11-18 of the guide. However, a new introduction to the guide explores the principles of plan management, which discusses expected behaviours in the delivery of plan management services.
|Achieving goals and outcomes||A plan manager should focus on supporting, and working together with a participant to manage their budget and better understand their NDIS funding and how to use it to achieve their goals|
|Ensuring Independence||This element is one of the newest inclusions to the guide. The NDIA encourages participants to engage with an independent plan manager who does not provide other NDIS funded supports to them. This will ensure that plan management services have no conflict of interest, and a participant is enabled to make informed decisions about the services and supports they engage with.|
|Demonstrating accountability||PMPS are required to:
|Increasing Consumer Awareness||PMPS are expected to:
CHANGING PLAN MANAGERS
A participant can decide to change plan management providers at any stage during their NDIS plan. When doing so, a participant and provider should agree on an end date, at which stage the PMP will no longer provide their services.
The guide then goes on to verify what the process of changing plan managers should look like when it comes to processing invoices. In other words, who processes the invoices?
Any invoice issued after the end date of the first Plan Manager, must be paid by the new Plan Manager. Of course, that makes total sense, and also stops Plan Managers denying that paying the invoice is their responsibility.
WHAT HAPPENS NOW?
As an outcome of this guide, we hope to see control put back into the hands of participants when it comes to their funding and gaining a greater understanding of what they can expect from their Plan Manager. We will also hopefully see Plan Managers review and improve how they intend to deliver their services, and provide greater support to participants.