Disability support markets in 2025
This paper outlines features of the future NDIS market that NDS would like to see
evolve and proposes strategies to guide their development. The National Disability
Insurance Agency (NDIA) has commissioned work from KPMG on the future NDIS
Market; and the COAG Disability Reform Council will consider advice on an
‘Integrated NDIS Market, Sector and Workforce Strategy’ in April 2015.
NDS believes that a future disability market should embody the following
characteristics:
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be contestable (with barriers to entry sufficient to protect minimum standards but
not poor performance)
be diverse (with respect to organisational size, structure, degree of specialisation
and how supports are delivered)
respond to the reasonable needs and choices of NDIS participants in all regions
of Australia
facilitate access to reliable information to support service development and
consumer choice
deliver effective social inclusion and economic participation for people with
disability
allow providers to be flexible, innovative and relatively unencumbered by red tape
value the social capital creation of not-for-profit organisations
encourage local connections and local responsiveness
foster collaboration between stakeholders, including with mainstream services
individualise most funding while acknowledging a role for bulk purchasing
provide risk-based safeguards for participants
deliver high-quality supports (and strengthen the nexus between price and
quality)
guard against the abuse of market power and anti-competitive practices.
Information symmetry
Providers need knowledge about demand to make good business and investment
decisions. Equally, participants need information and capacity to make sensible
choices. This can be facilitated with the following market infrastructure.
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Consumer demand data: The NDIA should facilitate dissemination of information
about market demand and supply to inform service development.
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Accessible and reliable consumer information and advice: The market will
generate information through provider marketing and consumer commentary.
National Disability Services
Disability support markets in 2025
However, this will not be sufficient to meet the full need for information. The NDIA
must invest in locally responsive information and advice services provided by
specialist associations and networks. This is consistent with the proposed
Information Linkages and Capacity Building (ILC) framework.
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Community-based local area coordinators: Local area coordinator positions
directly funded by the NDIA should be based in community organisations to
ensure they are well networked and accessible.
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Independent support for decision-making and planning: Some people require
communication and cognitive decision support, expert advice on technology or
specialist planning support.
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Investment in research and evaluation: Reliable independent evidence about
what works is essential for informed choice and service development.
Sustainable and diverse range of support options
The following infrastructure will help facilitate a contestable market that maintains an
equilibrium between demand and supply and sets fair and efficient prices.
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Evenhanded pricing: The NDIA should not fix prices. Participants should be
allowed flexibility in how they spend their funding packages through negotiation
with providers. The price assumptions that the NDIS uses to establish individual
packages should reflect fully the reasonable costs of support.
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Diversity: Services need to be responsive to diversity—culture, disability type,
gender, age, sexuality and geographic location – and the varied needs and goals
of people with disability.
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Market stewardship: We do not yet know what market conditions would erode
choice and control, the sustainability or quality of services. The NDIA therefore
needs to monitor the market carefully and be alert to potential market failure and
the abuse of market power.
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Policy settings that sustain the not-for profit sector: Over many years, notfor-profit services have built social capital, infrastructure and linkages which help
promote the social inclusion of people with disability. This value cannot always be
purchased. Charity tax concessions, some competition-policy exemptions,
preferential contracting for community services and investment in sector
development are all warranted.
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Bulk purchasing to ensure supply in thin markets: Speaking about aged care,
the Federal Disability and Ageing Minister, Mitch Fifield, recently stated: “to keep
some types of services available in the system we may need to continue a block
funding model…In addition there are some areas—particularly in rural and remote
areas—where a market can’t operate and other arrangements need to be put in
place.” This also applies to the disability market. In these situations, the NDIA will
need to contract for services, with appropriate checks to ensure contestability and
quality.
National Disability Services
Disability support markets in 2025
Risk-based quality control and safeguards
People with disability must be protected from harm through person-centred minimum
standards that are sensitive to different levels of risk related to individual
circumstances or types of support. The following market infrastructure will facilitate
quality, and safeguard against malpractice, without undue burdens or unfair contests.
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Promotion of knowledge about quality and rights: Abuse or neglect should be
recognised by anyone who comes across it and we should know how to respond.
Improving the general public understanding of disability rights will help achieve a
shared responsibility for quality and prevent bystander behavior. This includes
understanding that participants have the right to take personal risks and make
choices on the same basis as the rest of the population.
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Co-regulation: Co-regulation would entail an industry body that develops and
audits a code of conduct; an NDIA requirement for registered providers to sign up
to this code; a complaints body that gives direct voice and power to participants;
and underpinning legislation. This combination would replace existing disability
specific regulators and would collaborate with mainstream regulators and systems
such as the police, consumer affairs, ombudspersons and the Fair Work
Commission.
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A code of conduct: This code should be consistent with the National Disability
Service Standards requiring appropriate staff screening, supervision, training and
complaints systems. Auditing and quality controls should respond to a provider’s
record of conduct. Additional quality assurance accreditation and monitoring will
be required for services where choice and control is inherently reduced or there
are high risks of harm.
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National worker safety screening: There should be consistent and ongoing
criminal history check requirements for all community care sectors that use nonregistered staff, and a scheme to exclude non-convicted offenders who are
known, on the balance of probabilities, to have breached a code of conduct. This
system should allow employer discretion and contestability of screening providers.
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Fit-for-purpose industrial conditions: Industrial instruments need to support
working arrangements across a range of work hours and settings. It is also
important that an appropriate minimum floor is equally enforced to ensure
competition is based on quality and not at the expense of minimum labour
standards, including health and safety.
Investment in evidence and innovation
Long-term investment decisions should be informed by the life-time costs of support
and benefits of capacity development for individuals and support providers
(consistent with insurance principles). This requires evidence and innovation that can
be promoted by ongoing research and investment in sector development.
Towards a mature market
Sector needs during the transition phase will be different from the ongoing needs of a
mature market. The steep growth rate and large system changes comprise an
National Disability Services
Disability support markets in 2025
enormous challenge. The risk of undersupply causing deterioration in quality and
escalation of costs is palpable. To mitigate this risk, the following are essential
throughout the entire transition:
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reasonable prices that take account of the real costs of providing support and the
additional costs of transition
clear and timely communication on the implementation so providers can plan
ongoing effective engagement with stakeholders to enable co-design
transition support to ensure good providers remain viable where they are
identified as at-risk in thin markets
investment in capacity building for providers and workforce through sector
development and research funds
access to working capital to enable small organisations to grow
dissemination of early demand information to providers.
March 2015
Contact:
Dr Ken Baker
Chief Executive
National Disability Services
Ph: 02 6283 3200
[email protected]
National Disability Services is the peak industry body for non-government disability
services. Its purpose is to promote and advance services for people with disability. Its
Australia-wide membership includes over 1000 non-government organisations, which
support people with all forms of disability. Its members collectively provide the full
range of disability services—from accommodation support, respite and therapy to
community access and employment. NDS provides information and networking
opportunities to its members and policy advice to State, Territory and Federal
governments.