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Buying Internationally under the NDIS It is a requirement of the NDIA that all providers hold a valid and current ABN for all claims. This is true even of reimbursements made directly to the participant or their representative. What this generally means is that providers must be an Australian-based company. Some large international providers with an Australian presence will also hold an ABN and are therefore eligible for use with NDIS funding. Using Australian Providers In most circumstances, this means that overseas providers can not be utilised to provide supports or be used to purchase Consumables/Assistive Technology items. We will recommend that an Australian provider is utilised when possible. In some cases, using an overseas provider is the only viable option. This could be because there is no equivalent Australian provider that makes a certain item or provides a particular service. It is possible that these can still be funded, however there is an extra step in the process. The participant or their representative would need to contact the overseas provider to arrange the completion of an Australian Business Number (ABN) exemption form "Statement by A Supplier" (If a Statement-by-a-Supplier-Form is not able to be completed by the provider, then the participant will be unable to use NDIS funds for this purchase). This is a mandatory form that the Plan Manager must have on file before processing payments from any provider who does not possess an ABN, including overseas providers. All the usual criteria surrounding Reasonable & Necessary still apply. The support or purchases must still be linked towards the participant’s disability or stated goals. Invoicing best practices So that we can best process invoices and receipts for overseas providers, there are also some other criteria that must be adhered to. When payments are being made to the provider directly, we will require the invoice to be in Australian Dollars. When payments are being made to the client or their representative as a reimbursement, we will require the total amount in Australian Dollars in addition to a proof of payment and total amount. This is best provided with a screenshot of the transaction on a bank statement. Unneeded or sensitive information can be censored or cropped out.

What Providers Need to Know About Invoicing! Over the last few months, the PACE system has slowly become the new normal for many participants on the NDIS. We have seen that most new plans have been on the PACE system as it has gradually been rolled out nationwide since November 2023. With a significant number of participants now on the PACE system, we have put together a summary in this blog of the key changes that have been made in the last few months. Some of these have been covered in previous blogs, but there is always new information to learn about the NDIA and their processes. We have also summarised some of the additional changes that are affecting all participants, not just those on the PACE system. You can see our previous checklist for PACE supports here: First2Care PACE Checklist Changes to Assistive Technology Assistive Technology has been split into two separate categories. Assistive Technology (05) remains within the Capital Supports budget where required items can be purchased. This category is now solely for the purchase of equipment. Upkeep and rental costs for assistive technology has now been transitioned to the new category of Assistive Technology Maintenance, Repair, and Rental (19). This budget category can not be used flexibly with AT05 nor any other category. There is no requirement to update how invoices are written to ensure that the correct category is utilised. If the invoice states it is for repair or rental, then it will be correctly assigned. You can see our previous blog on Assistive Technology updates here: PACE and Assistive technology Rentals (first2care.com.au) Changes to Supported Independent Living Supported Independent Living (SIL) used to be included in the Assistance with Daily Life (01) category within the Core Budget. This has now been moved to its own category – Home and Living (16). This new category is not considered to be a part of the Core Budget and is therefore no longer flexible like it was previously. Because of this, it has become more important to ensure that invoices are correctly written to ensure that funding is taken from the correct category. Incorrectly processed SIL invoices taking from the 01 category can result in the Core Budget being rapidly depleted. If you are providing SIL support to a PACE client, you must ensure that you are using the correct description and codes on invoices. 01_801_0115_1_1 Assistance in SIL - Standard - Weekday Daytime 01_802_0115_1_1 Assistance in SIL - Standard - Weekday Evening 01_803_0115_1_1 Assistance in SIL - Standard - Weekday Night 01_804_0115_1_1 Assistance in SIL - Standard – Saturday 01_805_0115_1_1 Assistance in SIL - Standard – Sunday 01_806_0115_1_1 Assistance in SIL - Standard - Public Holiday Please note that these codes still utilise the 01 prefix, but they are allocated towards the new Home and Living 16 budget category. You can see our previous blog on SIL funding here: PACE Plans and Claiming Supported Independent Living (first2care.com.au) The NDIA also has resources on SIL supports here: Supported independent living provider guidance | NDIS Updates to Group Settings In January 2024, the NDIA completed an update to how Group Settings supports are handled. This change is for all NDIS participants, not just those on the PACE system. Claiming for group settings has been simplified to a single code. The 1:2, 1:3, etc codes have been retired from use. The following codes should be utilised based on when the supports were delivered: 04_102_0136_6_1 Group Activities - Standard - Weekday Daytime 04_103_0136_6_1 Group Activities - Standard - Weekday Evening 04_104_0136_6_1 Group Activities - Standard – Saturday 04_105_0136_6_1 Group Activities - Standard – Sunday 04_106_0136_6_1 Group Activities - Standard - Public Holiday The invoice should reflect the total hourly rate divided by the number of participants in the group activity. The combined rate from all participants must not exceed the capped price limits as set by the NDIA. All participants are still invoiced separately. For example, if you have a rate of $50/hr and provide group activities support for two clients, both would be invoiced a total of $25/hr. The NDIA have provided information on the changes to group setting supports here: Pricing arrangements | NDIS A reminder that this Group Settings update is for all participants on the NDIA, not just for those on the PACE system.

With the new payment process set by the NDIA in mind, it is more important than ever to ensure that invoices sent to First2Care are accurate and compliant to ensure that payments are made as quickly as possible. If we are having to chase clarifications, corrects, and amendments, then this will slow down the payment process as we are having to delay making a claim submission to the NDIA. Our commitment is to have invoices paid to providers within five business days of us receiving them. However, in order to do this, we need to ensure that we are not needing to follow up missing or incorrect information. When engaging with new providers, especially those who may not be familiar with NDIA requirements, it is best to discuss what information needs to be included on invoices. We have provided detailed information for providers on how to ensure invoices are correct here: Invoicing Tips for Faster Processing To summarise the previous blog, we have the following important information that should be included on every invoice: Correct client and provider details, including client name and NDIS number, plus the provider business name and ABN. Unique invoice number and invoice date. Date and description of support delivered, including support line code. Quantity of hours of delivered support. Hourly rate and line total. Invoice subtotal, correct to the sum of all line totals. You may check out the example invoice and the template to ensure that your providers are including all the correct information. Proof of Payment. This can be supplied either with a valid tax receipt showing payment method and a $0 balance, or with a screenshot of a bank transfer made to the listed provider if the receipt does not provide this information. An Order Summary is not sufficient information. A tax receipt is required. To ensure that any updated details are not missed, such as new bank details, we recommend using the Reimbursement Form for any reimbursements to be made: Submit Reimbursement | First2Care You can find more information on the best practices for reimbursements on our previous blog: How Do I Get Reimbursed?

Renting or hiring assistive technology (AT), is common practice within the NDIS space. Many of our providers, from therapists who conduct assessments to support workers assisting participants to utilise their AT in day-to-day life, will know that AT needs can change quickly. Under the NDIA’s new PACE system, AT rental has been separated from the general Capital AT budget and moved into a standalone category called Assistive Technology Maintenance, Repair and Rental (19). Because it is now in its own category, it is a little more restrictive. Funds within the Capital budget are stated, which means they must be spent in the way it is described in the plan. The NDIS are slowly transitioning plans over to PACE, which makes it important to support participants to ensure that if it is known that AT rental will be required and the plan is being reassessed, the request is made of the NDIA to add funding into the new category. While the NDIA’s operation guideline does note that participants may be able to use flexible plan funds to rent AT, we recommend that support coordinators, occupational therapists, and other providers involved in supporting participants with assessment and selection of AT rental items remain aware that the new category exists and the NDIA would expect that changes in AT needs should be made known so that funding can be added.

At First2Care, we aim to submit all invoices to the NDIA within one to two business days of receiving them. Given the NDIA then processes and releases funding within three business days of this receipt, our expectation is to have your invoices paid within five business days of you sending them to us. However, we do sometimes require a little assistance in this by your invoices being presented in a clear and concise manner. When submitting your invoices, we have several tips and tricks for being able to ensure that they are processed as quickly and efficiently as possible. We prefer that invoices are sent in a PDF format. This allows our system to automatically pick up much of the required details, skipping most of the manual data entry phase and speeding up the process. In addition to the format, the details that are presented on the invoice can make for a much quicker process. Provider Information Firstly, it is important to note who the invoice is for and who is being paid. To achieve this, the following information should be included on every invoice: Client Name and NDIS Number, Business Name, ABN, and Bank Details. Please note – to ensure that our automated system does not pick up the wrong details, do not include First2Care’s ABN anywhere on your invoice. Secondly, you should include the information unique to this invoice. This should be the Invoice Issue Date and the Invoice Number. Ideally, the combination of participant, provider, and invoice number are unique. Unless the invoice is an amendment, every invoice number for any given participant should be different. Supports Next comes the information about the supports provided. While all aspects of the invoice are important, the support description being incorrect or unclear is the cause of many payment delays. Therefore, by ensuring this is correct the first time around, payment processes should run smoother and faster. The Description of Service and the Support Item Code allow us to most accurately identify the support provided and which budget the invoice should be processed under. The description does not need to be detailed. It only needs to provide enough information to identify the supports, if a line code is not included. The line code should match the description and can be taken directly from the NDIS Pricing Arrangements and Price Limits document. Support Hours The quantity of hours worked is a crucial piece of information for the majority of supports. In almost all circumstances, this should be provided as a quantity of 1 per hour of support given per worker. The hours of supports should be broken down further as a per day total, which each day presented as a new line. Finally, there should be the unit price (most commonly the hourly charge) and the line totals. These line totals should then all be added together to produce the invoice total. You may check out the example invoice here and the template/s here to ensure that you are including all the correct information. Tips and Common Mistakes It is always best to double and/or triple check your invoices before submitting them. However, some areas may need more attention than others. Common areas where we have seen mistakes include: Invoice numbers aren’t unique – make sure you are correctly moving onto the next invoice number after submitting your most recent one. Repeated invoice numbers may result in invoices being deleted as a duplicate Participant name spelled wrong/NDIS number incorrect – we may not immediately recognise this invoice as belonging to one of our participants Incorrect item code – make sure the code reflects the support given. Errors may come from using a weekend code on a weekday, for example No hour quantity provided/incorrect – if we don’t know how many hours of support were provided, we can’t be sure it fits under the NDIS capped price limits. This will likely only be funded for a quantity of 1 hour of supports Incorrect date – if an invoice is future dated, we can’t process it. Likewise, if you have incorrectly put the date down as a weekday and claimed for a weekend support line code Charged over the maximum price limits – the majority of NDIS supports have a capped limit that we are unable to fund over. Please ensure you are keeping within these capped limits Incorrect line totals and subtotal – please double check your calculations to ensure the provided line totals and subtotals all match the quoted hourly charge and quantity of hours worked Rounding issues – the NDIA only calculates claims to a whole cent value. If your hourly charge or quantity of hours results in claims of partial cents, this can cause small discrepancies in the total paid Having the correct details on your invoices initially will result in fast and easy payment within our target of five business days. Any errors can cause delays as we will need to reach out to clients, representatives, or to yourselves to clarify and confirm the invoice details. If you follow these guidelines, we’re happy because there is less data entry and investigation work needed. You’re happy because you get paid in a regular and consistent manner. The NDIS is happy because the invoices are all compliant with their requirements. And, most importantly, our clients are happy because they have peace of mind that their providers are getting paid.

The new NDIS PACE system has gradually been rolling out nationwide for the last few months. For most participants now on the new system, this has resulted in minimal to no disruption to their NDIS experience. As with any new system, teething issues are always going to be inevitable, and this has impacted a few of our clients since November 2023. Given most of these issues have been reoccurring across multiple participants, we have put together this information for anyone expecting to transition to the new PACE system with their next plan. These will be important things to consider and to raise with your Support Coordinator or LAC in your plan review to ensure that your plan is suitable for your needs. Are you currently receiving, or are expecting to receive, Supported Independent Living supports? Supported Independent Living (or SIL) supports used to be included in the Assistance with Daily Life category within the Core budget. This has now been moved to its own category – Home & Living. We have noticed on occasion that the SIL funding on PACE plans has been incorrectly allocated towards the Assistance with Daily Life budget, which makes it inaccessible for SIL supports. To ensure continuity of your supports, make sure to raise with your Planner to ensure that Home & Living is correctly allocated. You may also need to request to your provider to update the support codes they use on their invoices, to ensure that they do not take funding incorrectly from your (likely, now smaller) Assistance with Daily Life budget. Are you currently receiving, or are expecting to receive, Assistive Technology rental or repair supports? Assistive Technology is another budget that has recently been updated with the new PACE system. Repairs and rental of Assistive Technology has now been separated into its own category. If you have previously been funded for the rental or repair of your purchased equipment, you will need to request with your Planner to ensure that the correct category is included in your plan. There is no requirement for your providers to update how they invoice. Are you new to the NDIS or wanting to join First2Care to help manage and navigate your PACE plan with you? Under the new PACE system, there is a requirement that a plan manager must have an approved relationship with a client. If a relationship request has already been lodged, then we are able to finalise set up of new clients. However, if this relationship has not been approved, then the client or an authorised representative will need to contact the NDIA to approve this. You can find the best contact information for the NDIA here: Contact | NDIS In your discussion with the NDIA, you will need to ensure that First2Care are correctly recorded as your plan manager. This will allow us to get access to the correct budget information. These are all responsibilities of the NDIA to ensure they are correct when new plans are set up, however with the freshness of PACE, some errors are understandable from time to time. The more informed you are going into the process, the better the outcomes tend to be for everyone involved.

Since the release of the much-anticipated NDIS Review in late 2023, participants, providers, and sector stakeholders have watched the dust settle and slowly begun to unpack the mammoth report and its recommendations. The general findings of the review point to several issues that have been known for some time and have made appearances in political rhetoric. Some of the key recommendations are: Improve the connection between participants not eligible for the NDIS and those that are, to better link mainstream services and the NDIS and develop a unified system of supports Establish a Navigation function to assist participants with making the best use of their funding Improve supports for children and participants with psychosocial disability Expand the registration requirements for providers delivering supports to participants Introduce a centralised digital payment system It is important to keep in mind that recommendations are not guaranteed to be implemented, and some of the recommendations would require many years’ worth of discussions, consultations, and design before they can be introduced to the NDIS. Navigators One of the recommendations is the establishment of the Navigator role. This would be an independent function that is in place to assist all people with disability, including those not eligible for the NDIS, to navigate the various systems and rules to get the most out of the support networks available to all people with Disabilities. Here at First2Care we have always taken the view that plan management is far more than paying invoices, even if that’s how the funding model has been set up. Navigating the many rules and regulations in the NDIS will always be critical, and we take pride in being able to offer evidence-based expert advice on using NDIS funds.

Since the rollout of the NDIS really hit its stride , a common concern raised by participants, advocates, and governments is equality in pricing for NDIS participants vs those not on the Scheme. The NDIS Review heard of the experiences of many participants who were able to demonstrate that the price they have been quoted for services or supports changed once their provider realised they were an NDIS participant. Minister Bill Shorten has been particularly vocal on the subject, and as of 15/12/2023 the NDIS Act has been amended to prohibit, without reasonable justification: Advertising a price for goods or services that is higher for participants than it is for someone who is not a participant; and Charging a price for goods or services that is higher for participants than it is for someone who is not a participant Price Limits vs Fair Pricing Something that can contribute to confusion in this area is that it is unrelated to the Price Limits set out in the Pricing Arrangements or other binding rules. To use assistive technology as an example, the NDIS sets out that low-cost items are those which are $1500 or less. If an identical item is sold to an NDIS participant for $500 and to a non-participant for $300, without reasonable justification, this would fall foul of the legislation. It is important to keep in mind that the NDIS does not dictate what can be charged, only what the maximum is. What this means for providers The change in legislation drives toward fair pricing practices to safeguard participants from price gouging or sharp practices in general. While most providers will not be affected by this, it is a good indicator of the direction that Scheme regulation is moving in, and an opportunity to review your billing practices. It is worth considering pricing structures that are in place to ensure that accidental overcharges are unlikely. The NDIS Commission expects that providers should be transparent with participants about pricing and be able to justify why a certain price has been charged. It is notable that the amendment does not specify any specific types of services or supports. In theory, this is a universal rule change but may impact some providers more than others, as participants and support coordinators may be more likely to request justification for the prices charged. For more information, check out the Commission’s resource page here: Fair pricing | NDIS Quality and Safeguards Commission (ndiscommission.gov.au) And the government media release here: Cracking down on unfair NDIS participant pricing | Department of Social Services Ministers (dss.gov.au)

The NDIA’s new PACE system has begun rolling out nationwide, with thousands of participants now transitioned to the platform. In most cases, the change has no impact on the day-to-day plan utilisation, but some key changes can result in confusion or difficulty. The creation of the Home and Living category of funding means that Supported Independent Living (SIL) is now no longer part of flexible core. This means that unless Home and Living is included in the participant’s plan, SIL cannot be paid. In this way, SIL is more akin to a standalone budget for capacity building than Core in the traditional sense that it has been known. Making sure the claim is correct The support items on page 45 of the current Pricing Arrangements and Price Limits should only be used for SIL, so it is important to know the difference between SIL and regular support work. The NDIS have some great provider resources on this: Supported independent living provider guidance | NDIS Make sure that the participant has Home and Living funding in their plan. We recommend establishing a service agreement (Service Agreements... Are they worth it?) and working with the participants, their support coordinator, and plan manager to ensure that the agreement aligns with the plan. Keep in mind that all new plans (not auto-extended plans) are likely to be on the PACE system. If a participant is living in SIL and their plan is approaching its end date, be sure to support participants and their support coordinators to specifically ensure that Home and Living is included in the new plan. If Home and Living funding has not been included, but a participant is in SIL, or about to move into SIL, the plan may have been built incorrectly. Supporting participants to submit a plan variation request to correct the plan is required in this situation.

Admittance to hospital can be a stressful and often difficult time for participants and their support networks. Questions can arise about who is responsible for what aspects of their daily care. In general, the NDIS is NOT responsible for funding day to day support for participants while they are in hospital, even if there are complex needs. Services if you’re in hospital | NDIS The health system has a universal obligation to all patients including people with disability and are responsible for making reasonable adjustments to meet individual needs. Non-hospital staff are also not likely to be able to comply with the hospital's requirements for insurance, patient care policies, equipment operation, and other workplace health and safety obligations. The health system is also responsible for clinical mental health support, both in and outside of hospital. Mental health and psychosocial disability | NDIS Plan Manager Responsibility As with any reasonable and necessary support, it is not up to the plan manager to pay or not pay an invoice if it is for supports delivered while in hospital. However, our role is to communicate the NDIS guidelines to you. What can be funded? The NDIS may fund Reasonable and Necessarysupports to: Give guidance and training for hospital staff working with participants with challenging behaviours. Give specific training to help hospital staff communicate with you if you have complex communication needs. Participants with complex communication needs or challenging behaviours may have their usual supports continue, however, it is recommended that this be discussed and agreed with the hospital and the NDIS. Click the button below to learn more about the: Principles to determine the responsibility of the NDIS and other service systems. Learn more about the NDIS principles(dss.gov.au). The NDIS also has Health Liaison Officers whose job it is to work with the hospital on a case-by-case basis with the goal of determining how the NDIS can support the participant to leave hospital and return to the community. Learn more about hospital discharge | NDIS

The NDIS is generally not set up to handle most emergency situations. If you are in a crisis and are in need of urgent or immediate attention, your first port of call should always be the emergency services. Should you be hospitalised, the majority of your supports covered by the NDIS will likely temporarily cease. The hospital, and therefore the medical system, will pick up the responsibility for your care, which is outside the purview of the NDIA. We have previously covered Supports in Hospital here: Supports in Hospital. Health services have an obligation to have ‘capabilities to meet the needs of people with disabilities’. This means that the NDIS will not fund supports provided in hospital, as these are expected to be covered by the medical services directly. Regular supports delivered by an NDIS support worker are generally considered inappropriate for delivering support in a hospital environment, as there may be additional demands like operating specialised equipment that they are not suitable qualified to manage. However, the NDIS may consider funding support workers in a hospital environment to: Give guidance and training for hospital staff should you have challenging behaviours. Give specific training to help hospital staff communicate with you if you have complex communication needs. Should your hospitalisation result in new of differing requirements from the NDIS on your discharge, a NDIS Health Liaison Officer can assist in arranging this. Most new plans in this situation are approved within 30 days of being admitted to hospital. Should you be impacted by a natural disaster, such as a bushfire, flood, or cyclone, this may impact the supports that you require. This may be because your Assistive Technology needs to be repaired, or you may need to leave your home for a short period of time. As before, should you be in immediate danger, the first contact should always be to the emergency services. While there are no provisions within the NDIS to add additional funding to plans during emergency situations, your regular funding can be used to fund additional supports or repairs as required. You may wish to consider a change of circumstances should this disruption leave you at risk of exhausting your funding. Invoices do not need any additional approval at this time. You may wish to discuss the situation with us so that we can ensure these additional invoices are processed without the need to check on their requirement. Assuming there is sufficient funding, we can process invoices during this emergency period. Assistive Technology is often a more complicated situation. Due to the increased cost, it is more likely that there is insufficient funding available. The NDIS will also only fund any given item once during a plan. You will need to submit a claim to the NDIA to approve a second purchase. This includes items such as mobility scooters, or approved beds and other such equipment. Emergency situations can be a challenging time, even without having to consider your NDIS Funding. Sometimes, the most important step you can take is to delegate authority to someone else – for example a Support Coordinator or a Nominee – until you are back in a more stable situation. While the NDIS is not equipped to handle immediate emergency care, it can certainly be there ready for you once you have returned to your regular situation. In the meantime, the relevant emergency services are more than capable to take over your supports while you require them.

There are some occasions where it is not feasible or possible for a provider to invoice a plan manager in order to fund a support or purchase. On these occasions, it may be more practical for a participant, or an authorised representative, to make a purchase out of pocket. This can then be submitted to a plan manager as a reimbursement claim. So that these claims can be processed smoothly, there are a number of important details to consider. Some of these may be requirements set by the NDIA, while others could be processes that we have put in place to ensure that nothing is missed and payments go through quickly. To best ensure that reimbursements go through quickly and efficiently, please go through the following tips and steps: Reasonable & Necessary The supports or purchases being claimed must fulfil the same Reasonable & Necessary criteria as any other payment made directly to a provider. We have previously covered Reasonable & Necessary guidelines here: Reasonable & Necessary… are there any exceptions? (first2care.com.au) ABN Even though we are not paying them directly, it is very important to note that all providers in a reimbursement claim must be eligible for NDIS funding. Essentially, this means that the provider must hold an active ABN. Tax Receipt As with invoices, a correct standard of invoice is required when submitting reimbursements to the NDIA. See our section below on invoice formatting to get a good idea of what is required. Receipts must include a clear description of the support/purchase, a date, and business information. These cannot be an EFTPOS receipt, an order summary, or a leaflet describing the service. A full tax receipt (or invoice with a $0 balance outstanding) is required. Proof of Payment Most tax receipts include proof of payment. For those that do not, we may request proof that this service or support has been fully purchased prior to making any reimbursement. Submit to First2Care There are two ways to submit your reimbursements to First2Care. The first is through the Reimbursement Form on our website, found on the Your Hub dropdown. This will prompt you to upload the necessary information and documents. Alternatively, you may email these directly to accounts@first2care.com.au – it is very important to include the word Reimbursement in the email subject. Bank Details If you have not already received a reimbursement from First2Care, you will need to provide us with your bank BSB and Account Number. The Reimbursement Form will prompt you for this. If the reimbursement is not to yourself, you will need to make it clear who is to be the recipient. Along with Reimbursements, you may also want your providers to have the best tips on how to get paid quickly. We have put together our advice on best invoicing practices in a seperate blog, which can be sent on to providers for their referral. Everyone loves to get paid quickly! Your best chance to get your reimbursement into your bank account quickly is to follow this process. Having a clear, official tax receipt is often the most important step. Any provider, large or small, should be able to issue a receipt that is sufficient to process. Sometimes you may need to request one. Check out Invoicing Tips for Faster Processing for more information on this. Invoices, including invoices submitted for reimbursement should be presented in a clear and concise manner, with certain necessary criteria as dictated by the NDIS. If your providers follow the below guidelines, your invoices can be paid quickly and your reimbursements will also be clear. The following information needs to be included on all invoices: Client name and/or NDIS number. Business name and ABN. Invoice Number. Description of supports with support codes if required. Quantity of hours if required. Unit price and Invoice subtotal. These details are required to process any payment – whether it is being sent to the provider or processed as a reimbursement. Once you have all the documentation needed, send it all through to us. If all is well, then you won’t need to speak to us at all until the money appears in your bank account! Though, of course, we are always happy to discuss your invoices should you have any queries.