Area Question Comment Improving Participant Choice and Control Discussion Point 1: More Choice for Participants What, if any, restrictions should there be (for example, region or distance) on participants choosing to attend a provider? How often should participants be allowed to voluntarily transfer or switch providers? What should be the basis of referral by Centrelink for participants who do not 1) Reasonable travel (3 hours or less; 1hour or less in a major metropolitan areas. 2) Participants should be able to move up to a maximum of two moves in 12 months not three. For participants who move there needs to be a pro rata of services that can easily and simply be administered. There also needs to be some protection that once a participant is placed in a job that they are not poached by another provider (without pro-ratapay). 3) Centrelink default mechanism should attempt allocate based on rotating algorithim to those service who can serve the key requirements of the participant based on the ESAT.
centred planning over the next six months. Driving greater competition and contestability in the delivery of DES Improving market access for providers through a DES Provider Panel How often should the Panel be open to entry by new providers? How often should panellists be reviewed and what criteria should they be reviewed against? What should the basic criteria be for joining the Panel? How much time do providers need before entering into a market to 12 months a short period for refreshing the panel, especially as the denominator in DES star ratings is 3 years not 2, making it very difficult to respond to market competition and consumer churn, turning around poor performance in time for the refresh. We would recommend 18 months or two years. Panel criteria should be against star ratings for performance, and other measures of quality (NSDS), goverance and financial strength. Minimum performance standard – 3 star or capacity to that within 12 months (provisional entry) For novel DES providers and new entrants performance should be established in a realted employment services market or disability support, with a provisional panel entry for 12 months based on performance in a small number of ESAs. Ensure CoAct can Panel register on behalf of DES provider partners
Discussion 10: Preventing Market Failure What specific should be as market failure If market share is continued in some areas, how should the level of market share be What should be used to address market failure and ensure service 10. 3 CoAct supportsa more active approach by the market steward in thin markets or where there is market failure by: A limited to stimulate consumer choice and appropriate supply response (facilitated and time limited) An increase to service fee to reflect the extra costs of the thin market other market challenges A minimum number of providers on of local consumer choices understand
Aligning incentives to support better outcomes Discussion Point 11: Ratio between service fees and outcome fees What should the ratio between service fees and outcome fees be and why? CoAct supports a stronger weight towards outcome fees but believes that new 52 week outcomes, funding to cover expected new NDIS participants and indexation of payments should be from new not cost neutral funds. Discussion Point 12: 4-week and 52-week Outcome Payments We support a 52 week payment but it should be funded from new not existing A four week outcome payment is also supported. Discussion Point 13: Service Fees How should service fees work in the context of a funding Recognise costs of transition to new system by tapering reduction of service fees over first 2 years Once we have a real costs study and a fully
model with outcome fees? reviewed and reformed assessment system, service fees could then be weighted proportionately like the outcome fees. Improved Gateway and Assessment Process Discussion Point 16: Improving the Gateway How can gateway be improved to enable a better to services for people with We support a review of assessments but believe this should not be rushed and should be on real costs and study in a cohort with controls to prove the assessment tool before it is deployed. The connection of the assessment to risk adjusted supports should be based on a real costs study. The context of assessments (skilled assessors, face to face, timeliness) should be addressed with increased
funding as necessary. Discussion Point 17: Assessments Review What other aspects of should be examined in the review? Should there be: greater of ESAts and own with ESAts focused on CoAct believes there may be merit in separating assessment for barriers and work readiness, from assessments made by providers of the range and cost of supports required for a participant. Providers’ assessments will necessarily be more strengths based, and will be based more on doing what is necessary to meet the employment objectives of the participants. We believe that the assessments review should involve real work and piloting of revised instruments rather than simple desk based actuarial review. This would mean taking up to 18 months to undertake the review.
Discussion Point 19: How can we better define when is to be at risk due to their How can we increase employer of JiJ? Does the current fee structure reflect the services being provided and outcomes disability One of the key issues of JinJ is requiring the engagement of the employer – may be part of the issues for a person with disability who has not disclosed in the workplace. Requiring employer engagement may not be necessary. Further details to make sure the specialist JinJ used by MS remains viable are attached. Jeopardy