NDIA RELEASES PLAN MANAGEMENT GUIDE

The introduction of Principles for Plan Management is new, however the principles are very narrow / operations focused in nature, with the exception of point 2.2.

2.1 Achieving goals and outcomes

Plan management providers should support participants with budget management and NDIS funded supports administration activities to achieve a participant’s goals and outcomes.

Plan management providers should work collaboratively with a participant to understand the funds available within their plan and provide advice about how to draw on this funding to achieve their goals and outcomes.

Nothing new here. RPMPs should support participants with Budget Management, Claiming Support and Provide information to participants about their spending including over and under spending.

2.2 Ensuring independence

Plan management providers must assist participants to manage the financial aspects of their plan without seeking to further the financial, or other interests, of themselves and their organisation, or any third parties.

This means plan management providers are required to have policies and processes in place to actively manage any real or perceived conflicts of interest.

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 are impartial, enabling a participant to make informed decisions about their support arrangements.

Section 4 of the NDIS Commission Code of Conduct (external) describes the expectations of providers to act with integrity, honesty, and transparency, which includes managing real and perceived conflicts of interest.

This is new and a step towards addressing conflict of interest within the Market. DIA welcomes the NDIA encouragement for participants to engage with an independent intermediary service (Plan Management and Support Coordination). DIA believes strongly in the independence Intermediary services and separation from all other supports and services.

 2.3 Demonstrating accountability

Plan management providers must provide information and advice to participants about the management of their NDIS funding to purchase supports in accordance with a participant’s plan budget.

Plan management providers must work with a participant to define how they will manage their funds. This includes defining the invoice authorisation process and keeping full, accurate records of required evidence (such as invoices) and information needed to monitor and make a claim for funds from a participant’s plan.

Plan management providers must provide a participant with regular (at least monthly) reports of plan expenditure and the balance of funds remaining in a participant’s plan. The plan management providers must also alert a participant of any risks associated with plan spending on services that will exceed a participant’s NDIS plan limit, or paying for supports and services not funded by the NDIS in a participant’s plan.

A plan management provider must have robust security processes in place to store and maintain participant information. Both the physical and electronic means of storing NDIS participant information must protect against unauthorised access. These records should be consistent with the Australian Taxation Office requirements.

The NDIS Commission Code of Conduct (external) provides additional information about what is expected of providers concerning the appropriate use and storage of participant information.

Nothing new in this section. The NDIA have again confirmed:

• RPMPs are required to provide information and advice to participants about the management of their NDIS plan funding;
• RPMPs are required to work with a participant to define how the RPMP will manage the participants funds including authorising and approval processes, this forms the basis of a Service Agreement;
• RPMPs are required to provide regular (at least monthly) information to participants about their plan spend. Many RPMP has online or app based dashboards, for providers who don’t monthly statements are also acceptable;
• RPMPs need to comply with registration requirements including the storage and use of participant information, see the NDIS Commission Code of Conduct.

2.4 Consumer awareness

Plan management providers are expected to uphold participant rights as consumers, and in line with their plan, enable a participant to exercise greater choice and control over the supports and services they engage.

These rights apply to disability items or services bought with NDIS funding, in the same way they apply to other goods and services. With the support of a plan management provider, a participant should be encouraged to make informed choices within the market.

Nothing new in this section. The NDIA have confirmed:

• RPMPs, like all providers, must uphold and deliver services to participants inline with Australian Consumer Law;
• RPMPs enable greater participant choice and control over supports and services, this is through greater support for funds to be used more flexibly (within current limits) and the use of non-registered providers;
• RPMPs should communicate with participants in the way that best suits them.

Generally this section is as per the current market offering for Plan Management, with some small changes to service around participants changing Plan Managers.

3.1 Planning and plan management

A participant can choose to have one or more of their funded supports managed by a plan management provider and this request can be made during a participant’s planning meeting.

If plan management services are requested by a participant, separate funding will be included in a participant’s NDIS plan to pay for the services of a plan management provider.

Noting new, the NDIA have again confirmed that

• the Participants has the right choose plan management to manage their NDIS plan funds; and
• separate funds will be provided to Participants who choose to have their plan funds managed by a RPMP.

3.2 Connecting to a plan manager

Participants are encouraged to select a plan management provider who best matches their preferences and needs. A participant can find and connect with a plan management provider in a number of ways, including:

• contacting a Local Area Coordinator, Early Childhood Partner, or support coordinator
• seeking recommendations from peer networks
• using the Provider Finder tool on the NDIS myplace participant portal, and
• exploring other online resources and websites including the NDIS Commission (external).

Participants are able to verify that their preferred plan management provider is registered by checking the NDIS Commission’s register.

A participant should have a clear understanding of the supports they have chosen and how they want their supports to be provided. When a participant engages a plan management provider, or any other provider, it is important to establish a service agreement.

A service agreement outlines the services to be provided by a plan management provider,
the duration of these services, the roles and responsibilities of both parties, how to resolve any problems, and what happens if either party wants to change or cancel plan management services.

Plan management providers are expected to use a participant’s preferred language and methodof communication when establishing a service agreement. This is to ensure both participants and plan management providers have a clear understanding of their agreement. More information about service agreements is available on the NDIS website.

Nothing really new here. DIA does believe that the connection process for participants to RPMPs could be greatly improved and continue to engage with the NDIA to explore improvements opportunities.

 3.3 Plan management services

There are two types of services that a plan management provider can provide, including: 

3.3.1 Plan management (financial administration)

Plan management refers to the financial administration of a participant’s NDIS plan on a participant’s behalf. This service will assist a participant by:

• managing and monitoring a participant’s budget in accordance with the plan management service agreement for the duration of the NDIS plan
• managing the NDIS claims and disbursing funds to providers for delivered services
• maintaining records for a participant and producing regular (at least monthly) statements for participants showing the financial status of a participant’s plan, and
• providing access as required to a wider range of service providers, including non-registered providers, while ensuring compliance with the price limits contained within the NDIS Price Guide.

Plan management funding is included in a participant’s plan, but is separate to the reasonable and necessary funding of a participant’s NDIS disability supports.

Plan management funding includes both a plan management establishment fee, and a monthly processing fee. The purpose of the establishment fee is to cover the initial cost for the establishment of financial arrangements between the participant and the plan management provider.

A meeting (face to face, telephone or other online engagement) between a participant and a plan management provider must take place for the establishment fee to be claimed. A record of the initial meeting must be maintained and the arrangements should formalised in the service agreement.

The monthly processing fee covers the ongoing costs a plan management provider incurs for the financial administration, payment of invoices, and monitoring of a participant’s plan budget.

The formilisation establishment process is new, but the majority of RPMPs already comply with such requirements.

The NDIA has written in terms of “a meeting”. The NDIA defines this to be face to face, telephone or other online engagement. DIA prefers the term engagement activity, instead of engagement meeting or initial meeting which the NDIA has used, as it more closely aligns with how participants engage with RPMPs.

Given that the ‘engagement meeting or initial meeting’ can be through a range of different delivery modes including “other online engagement” this means that this activity is more about gather information from providers and establish service and financial arrangements.

Providers must keep a record of this engagement activity (i.e. bundle of emails, record of phone call or tele-practice time or log of engagement through a website or platform) and with the engagement process being captured in RPMPs service agreements.

DIA believes that this is something that the market is able to achieve and has sort advise from the NDIA to confirm that this is not retrospective, so no RPMPs do not need to re-do existing service agreements if such engagement activities are not already included in their service agreement. RPMPs must include such engagement activities in service agreements moving forward.

3.3.2 Capacity building and training

Subject to a participant’s individual circumstances, ‘capacity building and training in plan and financial management’ may be included in the plan as a reasonable and necessary funded support. Funding for this support is separate to funding included in a participant’s plan for plan management services and is claimed at an hourly rate.

This capacity building and training support focuses on strengthening a participant’s
ability to undertake tasks associated with the management of their supports. This includes, but is not limited to:

• building a participant’s financial and administration skills to set and monitor budgets, pay providers in line with service agreements, and gain financial organisational skills
• enhancing a participant’s ability to direct their own supports including deciding who provides these supports and how they are delivered, and where possible and appropriate, developing a participant’s skills to self-manage their own NDIS plan.

Nothing new in this section. DIA notes that few participants are funded for this Capacity Building line items. DIA is actively engaging with the NDIA to drive greater inclusion of funding for this capacity building support.

3.4 What to expect when working with an NDIS plan manager

The development of the service agreement enables a participant and a plan management provider to agree on the level of service to be provided. A participant has the right to negotiate any terms included in a service agreement.

The NDIA encourages plan management providers to first meet with a participant to discuss and agree on the mode of delivery for plan management services. Service delivery modes available for participants and plan managers include a combination of face-to-face, telephone or other technology-based solutions depending on a participant’s preference and support needs.

The NDIA expects that a service agreement be in place so a participant and their plan management provider are clear about what each party has agreed to. These service agreements should reflect what has been agreed to between parties and include all terms such as pricing for NDIS services, establishment processes and dispute resolution. This service agreement 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.

If a dispute arises between parties, a service agreement can often assist. Plan management providers must ensure a participant or delegated decision maker fully understands and comprehends the terms of the service agreement and has the intention, capacity and capability to meet any obligations that rest with the participant.

Providers, including plan managers, should be aware of their obligations under Australian Consumer Law when creating a service agreement with a participant. The Australian Competition and Consumer Commission (ACCC) provide advice and information to businesses, including not-for-profit organisations, regarding the supply of goods or services to consumers with disability. The ACCC also provides information on consumer rights when an NDIS participant pays for a product or service themselves.

Nothing new in this section that hasn’t been metioned already. DIA notes that

• RPMPs need to establish a service agreement;
• Such service agreement should be understood by the participants or delegated decision maker (plan nominee or guardian etc);
• NDIA encourage RPMPs to ‘first meet’ with participants to discuss and agree on a service delivery model. Please see above in section 3, this ‘first meeting’ is really the engagement activity and includes engagement options like face to face, telephone or other online engagement. This facilitates RPMP’s that offer a completely online service option.
• RPMPs must meet and comply Australian Consumer Law.

3.5 Changing plan management providers

A participant can choose to change plan management providers at any time during the life of their NDIS plan, as long as a participant complies with the notice periods agreed in their service agreement.

Participants are encouraged to discuss the decision with their plan management provider prior to ending any working arrangement. In circumstances where a resolution cannot be achieved and a change of plan management provider is required, the plan management provider must assist a participant to transition to a new plan management provider.

Assistance should include providing a participant with information on whether any due or expected invoices are yet to be received and paid, and confirmation on what the plan management provider’s last day is for processing invoices. Ideally all services delivered during the period should be claimed by the current plan manager prior to transition. This reduces any service disruption and ensures continuity of plan management services to a participant.

If any issues arise with provision of plan management services, a participant can make a complaint about the quality or safety of NDIS supports and services provided to the NDIS Commission (external).

For complaints relating to plan management providers operating in WA, complaints may be directed to the Health and Disability Services Complaints Office (HaDSCO) (external) until 1 December 2020.

Providing assistance to participants when they decided to change to a different RPMP during the middle of a plan period is new. RPMPs are required to provide information to the exiting participant including:

• Confirmation on what the plan management provider’s last day is for processing invoices. DIA strongly recommends that RPMP’s include an approval clause in there service agreements to allow RPMPs contact all know providers of support to inform them of the Participants upcoming departure and the final date in which invoices will be accepted; and
• Provider participant with Final Statement, Report or Dashboard outlining:
  • All payments made during the current NDIS plan;
  • Whether any due or expected invoices are yet to be received and paid; and
  • Total plan spend and the current balance of funds.

Practically this can be a combination of the same statements or dashboard downloads a participant already receives (at least monthly).

A plan management provider is expected to manage a number of activities and tasks to ensure the effective financial administration of a participant’s NDIS plan. The activities and tasks should be applied in a way that recognises and supports a participant’s individual circumstances.

4.1.1 Scope of service delivery

During the initial meeting between a participant and a plan management provider, the scope of each parties roles and responsibilities should be agreed and comprise of:

• information about respective responsibilities to ensure supports obtained are aligned with a participant’s NDIS plan
• confirmation there is sufficient NDIS funding in a participant’s plan for supports
• a preferred method of invoicing and/or how receipts for reimbursement are exchanged
• a participant’s preferences regarding visibility over provider invoices sent to a plan manager
• a plan manager’s process for receiving and managing invoices
• responsibilities of a participant and plan management provider for ongoing monitoring and management of plan budget
• well defined and understood dispute resolution processes.

Nothing new, that has not been explored above, noting:

• ‘initial meeting’ with participants means the engagement activity and includes engagement via face to face, telephone or other online engagement. This facilitates RPMP’s that offer a completely online service option.
• All of these dot points should be contained in RPMPs service agreement.

4.1.2 Understand participant’s supports and goals

It is important for a participant and their plan management provider to discuss and agree on how they would like their NDIS funded supports to be managed. This includes having a clear understanding of how a participant wants to have invoices delivered to their plan management provider along with how, when and in what circumstances they would like to authorise claiming and payment for supports.

Plan management providers should discuss their own roles and responsibilities, in addition to those of the participant, regarding the engagement and payment of supports. This includes the plan management provider’s role of ensuring supports adhere with the NDIS Price Guide and are in alignment with the scope of the NDIS plan.

A plan manager must also advise a participant they cannot pay for supports and services
not funded by the NDIS out of their plan. These arrangements should also be reflected in the service agreement between the plan management provider and a participant.

Nothing new, that has not been explored above, noting RPMPs should as a part of their service agreement, establish a clear processes for:

• How the RPMP wishes to receive invoices;
• How and in what circomstances does the participant want to authorise the claiming for payment of invoices;
• How RPMPs will respond to participants when an invoice is received that is outside of the NDIS Price Guide or their plan funding.

4.1.3 Preferred method of communication

A plan management provider should ensure they communicate using a participant’s preferred communication method. For example, a financial statement of all NDIS plan transactions should be made available in an accessible and easy to understand format on a regular basis (at least monthly).

Again nothing new, RPMPs should agree to a preferred communication method with participant and/or participants formal decision makers.

4.1.4 Payment assistance

A plan management provider is responsible for processing payment requests through the NDIS myplace provider portal, or via other technology options available from the NDIA such as Application Programming Interfaces. Further information is available from the NDIA Digital Partnership Office.

Plan management providers must support a participant to understand the types of services and supports that can be claimed from a participant’s plan. A plan management provider must comply with the NDIS Price Guide using the most appropriate support items for claiming, including available support item code, how services can be used, and maximum prices that can be charged.

A plan management provider should increase a participant’s awareness of the NDIS Price Guide and how support items outlined in the guide relate to a participant’s plan. This will assist a participant to understand and direct their NDIS funds appropriately in order to achieve their goals, and prevent the under-utilisation of available NDIS supports or over-spending of their NDIS plan funds.

When plan management providers receive invoices or reimbursements that are not within a participant’s plan funding, or a plan management provider has identified a participant has potential for plan overspend, a plan management provider must immediately raise this with a participant or their representative.

Again nothing new. DIA notes:

• RPMPs must comply with the NDIA Price Guide and its controls;
• RPMPs can claim via the NDIA Portal (via PRODA) or through the use of API’s;
• RPMPs should help a participant to have visibility of the NDIS Price Guide, this does not mean RPMPs need to walk a participant through the entire guide and explain each line item, rather RPMPs need to inform a participant that whilst there is some flexibility there are limits set by the price guide such as maximum prices etc; and
• Again what to do if a RPMP receives an invoice that they can’t claim (i.e. insufficient funds, no funding for that support in their plan and/or outside price control limits).

4.1.5 Information regarding providers of supports

A plan management provider may be aware of available providers (including registered and non-registered providers) in a location where a participant lives and can provide this information where needed. While a plan management provider may choose to provide this information to a participant, the decision remains with a participant as to how they exercise their choice and control over the providers of the services they need.

A plan management provider is required to provide information to participants about:

• how invoices and receipts should be submitted by providers to the plan management provider for payment (refer 4.2.1 of this guide)
• any tasks required by a participant or their provider to ensure timely payment of services delivered
• the minimum information requirements for invoices or receipts (refer 4.2.1 section of this guide)
• the need for a participant to periodically confirm invoices have been correctly paid
• a participant’s right to make a complaint or provide feedback on services received as it relates to the NDIS Commission’s Code of Conduct (or in the case of providers in WA) the NDIS Terms of Business.

Again nothing new. DIA notes:

• RPMPs can provide service recommendations to participants, however it is not a RPMPs function to deliver Support Establishment functions, this is the role of a LAC or Support Coordinator to support a Participants decision making and service establishment.

4.1.6 Fees

A plan management provider should explain their schedule of fees which may be documented in
a service agreement and must comply with the NDIS Price Guide.

For additional information regarding plan management fees refer to the NDIS Price Guide.

Again nothing new.

4.2.1 Prompt payment

While engaged as a participant’s plan management provider there is an ongoing responsibility for monitoring NDIS plan funding and paying for supports delivered to a participant.

A plan management provider must validate whether invoices received from providers of services are in accordance with the plan and in line with expected NDIS plan spend within no more than five business days. This promotes efficient plan reporting and management, and ensures a provider’s original invoicing terms are met.

In circumstances where an invoice or receipt is received and found to be outside the scope
of a participant’s funded supports, the plan management provider should discuss the invoice with a participant as soon as practicable and refer a participant to the provider for further discussion.

Tax invoices or receipts received by a plan management provider should contain clear details to enable accurate processing.

Tax invoices must include enough information to clearly determine the following details:

• that the document is intended to be a tax invoice
• the provider’s identity, and their Australian Business Number (ABN)
• date the invoice or receipt was issued
• a description of service or support delivered
• the GST amount (if any) payable – this can
  be shown separately or, if the GST amount is exactly one-eleventh of the total price, such as a statement which says ‘Total price includes GST’
• the extent to which each sale on the invoice is a taxable sale (that is, the extent to which each sale includes GST)

Where appropriate, as many of the following details are also expected to be included in an invoice:

• the participant’s NDIS number, and their name
• quantity of service or support delivered
• the total cost of service delivered and invoicing amount date(s) of service or support delivered
• location of supports delivered
• NDIS support item name and number (if known) and
• details of how payment should be processed.

Participants seeking reimbursement for services must provide a plan management provider with a receipt containing the same information as the tax invoice issued from their chosen provider of supports (as stated above).

The participant and their plan management provider must discuss and agree on how to approve or authorise invoices for claiming from the NDIS. A participant may wish to give the
plan management provider pre-approval to
claim for some invoices, such as scheduled or regular supports and invoices that might not change much over the course of the plan period. Alternatively, a participant might wish to approve every invoice prior to claiming. This arrangement should be defined and clearly captured in the service agreement prior to commencing claiming.

The NDIS Commission publishes a compliance and enforcement actions register in accordance with the NDIS (Provider Registration and Practice Standards) Rules 2018, which is available on the NDIS Commission’s website. Plan management providers should alert participants to the existence of this register and ensure plan funds are not paid to a provider, or individual, with
an active banning order issued by the NDIS Commission.

A plan management provider should arrange for a prompt payment to a service provider, or prompt reimbursement to a participant, within two business days of the plan management provider receiving payment from the NDIS.

DIA notes:

• RPMP responsibility to monitor and manage a participants NDIS Plan Managed funds;
• RPMPs must ‘validate’ received invoices within no more than 5 business days. This validation includes:
  • Services are in accordance with the plan. i.e. the participant plan has funding for this type of service; and
  • Such invoice is in line with expect plan spend. i.e. if a large unexpected invoice appears it is important for the RPMP to communicate with the participant to ensure this service was delivered and what impact it may have on their total plan funds.
  • This point does not mean a RPMP needs to audit or ensure that the service has been delivered in line with all NDIS policy, rules or requirements. Rather RMPMs need to review the invoice to ensure that it complies with NDIA claiming rules and NDIS Price Guide.
• Again what to do if a RPMP receives an invoice that they can’t claim (i.e. insufficient funds, no funding for that support in their plan and/or outside price control limits).
• DIA welcomes the NDIA, defining that must be and what should be included on invoice – FINALLY, AWESOME NDIA!
• NDIA has confirmed that participants seeking reimbursement for services must provide a RPMP with a receipt containing the same information as required for a tax invoice.
  • DIA notes that many providers also accept a Statutory Declaration from participant for re-reimbursements where a receipt has been misplaced, or not adequately issued.
• Again, RPMPs should agree with a participant as to how and in what circumstances the participant wants to authorise the claiming for payment of invoices, this may include pre-approval for regular and know supports;
• RPMPs should arrange for prompt funds disbursement to providers within 2 business days of receiving funds from the NDIA. DIA believes that this requirement to disperse funds to providers within 2 business days must be from when a RPMP receives both the funds and remittance statement / report form the NDIA.

4.2.2 Payment integrity

A key component of a plan manager’s role is to manage and acquit the funding for supports that have been approved in a participant’s plan by the Agency. This component of a plan manager’s role includes paying for the supports that are identified in a participant’s plan.

Ultimately, all plan managers have a legal responsibility to ensure that NDIS funds (public monies) are spent in accordance with the participant’s plan. In discharging this obligation,
it is important for plan managers to consider that supports in a participant’s plan can either be described generally or specifically. Where supports in a plan are described generally, the participant will have a high degree of flexibility over the implementation of their supports. In contrast, supports that have been described specifically (known as ‘stated’ supports) will have to be purchased in the way described in the plan.

To ensure maximum choice and control, where possible the Agency’s preference is to describe core supports generally so as to provide participant’s with greater flexibility surrounding the supports they can purchase to move them towards their goals. However, given each participant has an individualised plan, the plan manager will need to ensure that funds have been spent appropriately having regard to the supports approved in each participant’s plan.

To be clear, the role of a plan manager does not extend to determining whether supports
or services which have been purchased are ‘reasonable and necessary’. The participant’s individualised plan will already have funding included for the reasonable and necessary supports that have been approved by the Agency at the planning stage. As stated above, the plan manager’s role is to ensure that the participant’s plan is being implemented as intended, which includes ensuring that funds are being spent in accordance with the plan and in line with expected NDIS plan spend. In addition, a plan manager’s role does not extend to deciding what supports a participant can access.

It may be the case that a participant is spending their NDIS plan funds faster than anticipated and there is a risk that funds will be exhausted before the participant’s next scheduled review date. In these circumstances, a plan manager should engage early with the participant in relation to the effective and efficient utilisation of the approved funding throughout the expected plan period. Where a participant needs additional funding (for example, due to a change in circumstances), the participant can contact the Agency directly to discuss the options that are available to them.

Inappropriate use of government funds or fraud are serious matters. A plan manager may be liable to repay any amounts which have not be spent in accordance with a participant’s plan. Additional information is available on the NDIA’s Provider Payment Assurance Program which outlines expectations of providers regarding claiming.

Plan management providers must follow payments and pricing controls established by
the NDIA. This includes abiding by, and not exceeding, price controls set out in the NDIS
Price Guide. Plan managers are unable to pay an invoice for a support that exceeds the relevant price control, irrespective of whether a provider seeking payment is a registered or non-registered provider.

Plan managers cannot claim funds from a service booking in advance prior to supports and services being delivered to a participant. Plan managers can only claim from a participant’s NDIS plan once a support has been delivered or provided, and an invoice or receipt has been raised showing the relevant information about the type of service and when a service was provided to the participant.

What does all this mean?

• RPMPs must have enough information to reasonably lodge a claim on behalf of a participant. RPMPs should ask themselves:

1. Does the supplied invoice or receipt contain enough information to match to the participants plan?
2. Does the participant have funding in their plan for this support / service as described on the invoice?
3. Does the invoice comply with the NDIS Price Guide?
4. Is there enough funds within the participants plan to pay for this invoice?
5. Do I (the RPMP) have approval to lodge a claim for this invoice? (i.e. has this support been pre-approved or does the RPMP need to seek approval).

• DIA welcomes the messaging from the NDIA the RPMPs are not responsible to determine if supports or services which have been purchased are ‘reasonable and necessary’ and that a plan manager’s role does not extend to deciding what supports a participant can access.
  Rather it is the RPMPs responsibility to determine if supports or services which have been purchased, with provided invoice or receipt, are in compliance with the NDIA Price Guide and able to be claimed from the participants NDIS plan funds.
• RPMPs need to inform a participant about their spending behaviour and alert them to potential over and under spend patters.
• This bit RPMPs might find controversial: “Inappropriate use of government funds or fraud are serious matters. A plan manager may be liable to repay any amounts which have not be spent in accordance with a participant’s plan. Additional information is available on the NDIA’s Provider Payment Assurance Program which outlines expectations of providers regarding claiming.

  What does this mean? Fraud and misappropriation of government funds is serious, recently there has been a number of public cases where the NDIA has sort civil and criminal action against fraud. This paragraph is highlighting that where a RPMP engages in such fraudulent and misappropriation activities they will likely be investigated and liable to repay claimed amounts and other possible penalties under the Law.
  This draws back to the point above about RPMPs asking themselves where they have enough information to lodge a claim. The NDIA understands that RPMPs are not responsible for the fraud and misappropriate activities that might be undertaken by other providers or participants (i.e. RPMP receiving fraudulent invoices with participant approval to claim), save for where the RPMP is a knowingly and willing participant in the fraud or misappropriation.

• Again RPMPs are bound by the NDIA Price Guide and as such RPMPs cannot claim funds from a service booking in advance prior to supports and services being delivered to a participant.

4.2.3 Plan spending information

At a minimum, a plan management provider is required to issue monthly financial statements to a participant. The statements should include:

• a report which details a participant’s NDIS plan spend since the previous issued statement
• the remaining balance of funds in a participant’s plan
• an indication of whether a participant’s plan spend is consistent with, above or below the forecasted plan spend.

Frequent plan utilisation reporting and timely payment processes both mitigate and prevent over-expenditure risks. It is best practice for a plan management provider to support a participant by providing access to real time monitoring of plan funds through a variety of communication methods that include use of an online portal or application, phone or email.

A plan management provider is expected to signal any concerns relating to over or under-utilisation of NDIS funds to a participant and their nominee, as part of the plan statement.

A participant may be responsible for any charge, and costs related to plan overspend.

Broader (non-financial) support to a participant to assist with implementation of their plan is undertaken by a support coordinator or NDIS Partner in the Community (Local Area Coordinator, or Early Childhood Partner). An NDIS Partner in the Community or support coordinator may assist a participant to resolve NDIS plan over or under- utilisation.

DIA welcomes much of this information and notes:

• RPMPs need to provide participants with regular information about their plan budgets and spend, this can be done via monthly statements, dashboards, apps, online platforms etc.
• Again, RPMPs should signal possible over and under spend occurring within the participants plan.
• Participants are ultimately responsible for the services they engage and the service agreements they execute. As such they may be directly liable for charges and costs that are not covered by their NDIS Plan, including overspend.

4.2.4 Change of plan manager statement

If a participant is looking to change their plan management provider, the plan management provider should generate a financial statement outlining all payments made during the current NDIS plan and provide this to a participant. This statement will assist a participant’s transition to a new plan management provider and help to ensure the timeliness of payments, as well as ongoing supports and services.

The report must also identify a participant’s total plan spend and the current balance of funds. The statement is to be in a format that is accessible and preferred by a participant.

This is new, as mentioned above RPMPs are required to provide information to the exiting participant including:

• Confirmation on what the plan management provider’s last day is for processing invoices. DIA strongly recommends that RPMP’s include an approval clause in there service agreements to allow RPMPs contact all know providers of support to inform them of the Participants upcoming departure and the final date in which invoices will be accepted; and
• Provider participant with Final Statement, Report or Dashboard outlining
  • All payments made during the current NDIS plan;
  • Whether any due or expected invoices are yet to be received and paid; and
  • Total plan spend and the current balance of funds.
    Practically this can be a combination of the same statements or dashboard downloads a participant already receives (at least monthly).

4.2.5 End date for processing invoices

When a participant decides to end a service agreement for plan management services, a participant and a provider should agree on an end date, at which time a plan management provider will no longer provide their services. This means that any invoices issued after this end-date, and associated payments, are the responsibility of a participant and their new plan management provider to process.

A participant is required to provide details of their new plan manager, including information on where to send future invoices, to their existing providers to ensure continued prompt payment.

In any transitional arrangement a new plan manager may need to pay money spent from a participant’s plan, even if the expenditure was incurred before their agreed start date. This is
to ensure any late invoices issued by a provider from earlier in the plan period are able to be paid. However while this is possible, the NDIA expects payments of this kind will only be required in exceptional circumstances.

In order to process this type of payment, plan managers will need to create a ‘plan managed’ service booking for the entire plan period, rather than the date they commenced delivery of plan management services.

Nothing new. DIA notes:

• New plan managers will be required to process claims and receive invoices for participants that may be for services prior to the engagement of a new RPMP;
• To save on administration activities and burden, DIA strongly recommends that all RPMPs create a ‘plan managed’ service booking for the entire plan period, rather than the date they commenced delivery of plan management services. There is no way for a new RPMP to be 100% sure that they won’t receive an invoice for participant service prior to their engagement. Creating a plan managed service booking for the entire plan period will facilitate quick processing of any invoices that may come between the exit of the old RPMP and the engagement of the new RPMP.

4.3 Duties outside the scope of plan management

A plan manager’s role is to support a participant by managing the funding of supports in their NDIS plan. Their role relates specifically to the financial, plan-managed funded supports of the NDIS Plan and does not extend into supporting with day-to-day administration, management
or maintenance of the entire NDIS plan. A plan manager has different roles and functions to
the plan implementation support provided by an Local Area Coordinator, Early Childhood Partner, or Support Coordinator.

A plan manager is not responsible for assisting the participant to explore and connect with providers, broader systems of supports, and community supports. A plan manager is also not expected to maintain a participant’s NDIS supports through rostering services, or providing disability related advocacy services.

DIA welcomes this and notes RPMPs are not responsible for:

• NDIS plan implementation;
• Assisting the participant to explore and connect with providers, broader systems of supports, and community supports; and
• Maintaining a participant’s NDIS supports through rostering services, or providing disability related advocacy services.