DSC reports that;
… from 1 March 2020, NDIS participants will be able to spend their funding more flexibly on transport. But be warned – while we welcome this long awaited change, there are parts of this announcement that are very problematic and the transport issue is far from fully resolved.
FLEXIBILITY IS NOT JUST IN CORE SUPPORTS
The updated Support Catalogue has added 9 new line items under 6 different support categories:
- Assistance with Social and Community Participation
- Improved Living Arrangements
- Increased Social and Community Participation
- Improved Relationships
- Improved Learning
- Finding and Keeping a Job (excl. SLES)
This means that people should be able to use their core funding on transport (but only to certain places – see below), as well as their funding in the additional 5 capacity building support categories. The line item name and description is the same in every support category:
People will need to have funding in one of the above support categories to claim transport costs using these line items and it appears they may not need to have a transport allowance in order to do so. This is great news for people who have not been able to fund the cost of transport to their NDIS-funded community activities.
PEOPLE CAN ONLY PAY FOR TRANSPORT TO PLACES WHERE THEY WILL BE SUPPORTED BY THE TRANSPORT PROVIDER
Here’s the bad news. The Price Guide has created 2 new definitions of transport:
- General Transport Services: Transport to “an activity that is not itself a support – or to a support that is delivered by another provider.”. This category includes transport to mainstream supports and friends/family, services delivered by other providers and everything else in life that doesn’t involve service providers. There is no increased flexibility for this type of trip, which still needs to be paid from a person’s transport allowance.
- Activity Based Transport: Transport “to, or from, or as part of, a community participation support”. Think things like supermarket trips with a support worker, going to the footy with a support worker or going for a coffee – you guessed it – with a support worker. This is the type of transport that can be claimed from the new line items.
To summarise: people will only be able to claim from the new transport line items if they are going somewhere where they will be supported by the transport provider. So unless your Uber driver is also your support worker, taxis and rideshare cannot be claimed. And if someone wants to independently try out a local choir or dance class, they won’t be able to claim the cost of getting there, regardless of their mobility or how they manage their funds.
We don’t need to point out (but we will anyway) that this creates a perverse incentive for people to use paid support where they may not need it and disadvantages people who are exploring life outside of NDIS services. It is baffling why an insurance scheme would hold this position and we can only hope it is somehow a massive misunderstanding that will soon be clarified. Fingers crossed.
TRANSPORT MUST BE TO A “COMMUNITY-BASED” ACTIVITY
The definition of Activity Based Transport includes the stipulation that the support must be “community based”. Typically the Price Guide differentiates between “community based” and “centre based”, which suggests to us that these line items should potentially not be used for transport to and from centre-based programs. We could very easily be wrong about that but if “community based” doesn’t mean “not centre based” then we’re at a loss at exactly what it could mean.
PRICES ARE NOT CAPPED
Last week’s announcement made reference to what appeared to be 3 price limits for transport, stating:
Participants and providers can discuss and agree on non-labour costs, when arranging a service booking, including:
- up to $0.85 a kilometre for a standard vehicle not modified for accessibility;
- up to $2.40 a kilometre for a vehicle that is modified for accessibility or a bus; and
- other forms of transport or associated costs up to the full amount, such as road tolls, parking, public transport fares.
These price limits are absent from the updated Support Catalogue, which actually notes that transport is not a price controlled support. They are, however, included in the updated Price Guide,which states “The NDIA considers that the following would be reasonable contributions”, which we have to interpret to mean they are merely a helpful suggestion.
The non-labour costs that are considered in these “reasonable contributions” include road tolls, parking fees and the running costs of the vehicle and they are designed to be charged in addition to the relevant hourly rate for the worker’s time.
IT DOESN’T SEEM LIKE THE PORTAL HAS CHANGED
The major barrier to date in people being able to spend their core funding flexibly on transport has been the portal and specifically, who it allows to make payment claims in the Transport support category. People who do not have transport funding in their plan or who receive all their transport funding as a direct fortnightly payment have historically not been able to make claims in the transport support category. This announcement has not changed that.
What this announcement has changed is introducing new line items (none of which are in the Transport support category) for a specific type of trip. It’s a solution that goes a long way but not all the way towards solving the transport problem, addressing the issue for most service providers but not for many NDIS participants.