NDIS Plan Management Strategy

For Providers who are registered to deliver NDIS Financial Plan Management (FPM) Services, the information outlined in this article lists the functionality in SupportAbility available to manage these operations. 

Overview

SupportAbility's NDIS FPM functionality includes: 

• additional privacy barriers for all Client Journals associated with NDIS FPM Services inherently,
• the ability to enter Plan Managed NDIS Client Funding records. These records represent the Funds your organisation is managing on behalf of the Client, and facilitate the charge of fees for this Service,
• entering External Invoices received from NDIS Service Providers in the FPM tab for Clients who your organisation provides financial intermediary services for,
• External Invoice Batch exports of these Invoices for your Finance System, in Accounts Payable and Accounts Receivable formats, and 
• Generating NDIS Bulk Payment Requests, including the Invoice Items entered in approved External Invoices. 

Privacy

When a Service has been set up as an ' NDIS Financial Plan Management (FPM)' Service in SupportAbility, not only does this activate the Plan Management functionality, this setting also creates additional privacy barriers for Client Journals associated with NDIS FPM Services. 

This ensures that Staff must have access to not only the Client that the Journal entry is for, but also Plan Management Services specifically, in order to see these Journal entries. 

These restrictions help to ensure conflict of interest compliance requirements are maintained. 

NDIS Plan Managed Client Funding records

The NDIS Funds your organisation is managing on behalf of the Client must be added as an NDIS Plan Managed Client Funding record. Once this has been added, NDIS Supports can then be allocated as Invoice Items when entering External Invoices into the Client's FPM tab for inclusion in the NDIS Bulk Payment Request file for claiming. 

Most providers offering Plan Management Services, enter the Budgets for the Client's NDIS Plan Managed Funds at the Support Category level, which reflect the total value of funding that they will be managing on behalf of the Client. This usually aligns with the Plan Managed Service Booking. 

However, if your organisation is also delivering Direct Services to the Client's you are providing Financial Intermediary for, the way in which your organisation wishes to manage Client Funding and Invoice Processing will need to be considered. The chosen approach will result in different ways to configure this record. 

For comprehensive overview of this record, along with setting it up please watch the  NDIS Plan Managed Client Funding video in the Client Funding section of the Learning Centre. 

Managing Direct Invoices and Plan Management Invoice Processing 

Invoices and Invoice Processing functionality is available in SupportAbility for organisations delivering the following NDIS Services:

• Direct: Services delivered directly to the Client which are then invoiced based on how a Client's Funds are being managed. Either, to the Client, their Nominee, the NDIS Plan Manager or claimed in a Payment Request from the National Disability Insurance Agency (NDIA). Or, a combination of these methods. 
• Plan Management: A Service that entails processing NDIS Invoices for Direct Services delivered to the Client.

Since the introduction of NDIS intermediary services (Plan Management and Support Coordination), the role and responsibilities of Plan Managers has not been clearly defined by the NDIA, and no concrete guidance has been provided to explain how Plan Managers are expected to conduct operations other than the ethical guidelines previously mentioned. Both the NDIA and the National Disability Services (NDS) have recognised these issues and have recently undertaken a review process in consultation with the sector in an effort to better understand and clarify the role of NDIS intermediary Services, like Plan Management.

This lack of operational guidance, coupled with the current price limits for delivering Plan Management Services, along with the seemingly redundant operational overhead of an organisation invoicing itself, has lead providers to seek more efficient operational pathways or 'shortcuts' to reduce overheads to gain profitability. To this extent, many Service Providers delivering both Direct and Plan Management Services for specific Clients often chose to bypass the process of invoicing and paying themselves and instead focused purely on the actual outcomes of the process as a whole. This being for the organisation to deliver Direct Services to the Client and then receive funds from the NDIA for the value of these Services delivered.

Compliance and Governance

The Terms of Business for Registered Providers under the NDIS outlines the importance of avoiding and managing both potential and actual conflicts of interest through organisation policy and action. 

In March 2016, before the NDIS was even out of it's trial phase, the Australian Competition and Consumer Commission published A guide to competition and consumer law for businesses selling to and supplying consumers with disability, outlining the key competition and consumer protection obligations of Service Providers operating under the NDIS.

In July 2018, the NDIS Quality and Safeguards Commission was established and published the NDIS Code of Conduct for NDIS Providers, to 'promote safe and ethical service delivery, by setting out expectations for safe and ethical services and supports for both NDIS providers and workers.'

In situations where a single organisation is responsible for both invoicing and paying those invoices, the potential risk for conflict of interest increases dramatically. Therefore it is critical that providers of both Direct and Plan Management Services consider these compliance frameworks and obligations before deciding how to use SupportAbility to achieve the required outcomes.

To reduce risks associated with conflict of interest, it is recommended that organisations delivering both Direct and Plan Management Services to Clients, make efforts to separate these concerns by focusing on:

• Privacy 
  • Ensure that Staff working in Direct Services cannot access Plan Management information and vice versa. Restricting access to information in this manner greatly reduces the potential for conflict of interest incidents.
• Consistent process 
  • Direct Service Invoicing
    • When Direct Services are Invoiced these are directed to the required debtor based on the Client's requirements for Fund management. In situations where your organisation is the Plan Manager, Invoices should be issued to your organisation in the same manner as any other Plan Manager would be Invoiced. 
  • Plan Management Invoice Processing  
    • Invoices received from NDIS (Direct) Service Providers should be processed in the same manner regardless of whether the Services were delivered by your own organisation or by a third party Service Provider.
• Evidence
  • It is important that an organisation can produce transparent and auditable supporting evidence when required, in order to demonstrate that appropriate policy is in place and being managed, to meet compliance obligations.

Invoice Processing - recommended approach

A diagram of the operational workflow, the detail of each step involved and a summary of the benefits and drawbacks is outlined here. 

Operational workflow - diagram

Select this link or the image above to view the full sized version. Once open, this can be downloaded by saving the PDF as required. 

Operational workflow - steps

Benefits and Drawbacks

Invoice Processing - shortcut approach, not recommended

A diagram of the operational workflow, the detail of each step involved and a summary of the benefits and drawbacks is outlined here. 

Operational workflow - diagram

Select this link or the image above to view the full sized version. Once open, this can be downloaded by saving the PDF as required. 

Operational workflow - steps

Benefits and Drawbacks

Steps to set up and use the NDIS FPM functionality

Once your organisation has reviewed this important foundational information regarding Financial Plan Management, we recommend reviewing the Steps to set up and use the NDIS FPM functionality article next.