Obligations of Therapy Providers Delivering NDIS Support

Recently, the NDIA/NDIS Quality and Safeguards Commission has contacted plan managers, support coordinators, and allied health providers, reminding them of their responsibilities to ensure that the scheme is implemented as intended. The NDIA has made it clear that they will be taking more time to audit payments coming through before payment is made. This audit is said to be in place to reduce the number of fraudulent claims, non-compliant claims, incorrect claims, and overcharging currently occurring.

For this article we are focusing on Improved Daily Living (Therapeutic Supports).

The NDIS Pricing Arrangements and Price Limits document clearly defines who is allowed to charge from certain categories, what qualifications they must hold, and which regulatory body they must belong to.

A provider who does not hold the relevant therapy qualifications and registrations is not permitted to use therapy codes and the subsequent rates when billing. It would be against the NDIS Code of Conduct if this was being done knowingly in practice, potentially detrimental to the participant's safety, and a gross misuse of their NDIS funding. To find more out about provider compliance, head to the NDIS website. 

When invoicing for NDIS services, it is good practice to list the practitioner along with their practitioner number. This ensures minimal delays and reduces the chances of the invoice being audited by the NDIA. Below is a complete list of all registrations in the NDIS Pricing Arrangements and Price Limits document (version 1.2, 2024-25, released 9 July 2024, valid from 1 July 2024).

Qualifications for delivering therapy to children:

Early Childhood Supports (EC), supports delivered to children under the age of 7 are expected to be delivered in line with the NDIS Commission’s NDIS Practice Standards and Quality Indicators for Early Childhood Supports. The below listed therapy supports can only be used for children under the age of 7.

• Developmental Educator – A person who has a bachelor's degree or higher and has current full membership with Developmental Educators Australia Inc.

• Early Childhood Teacher or Educator – A person who has a bachelor's degree or higher in Early Childhood Education or Special Education, who, where applicable, has a current registration or accreditation with their state or territory's relevant professional body.

• Occupational Therapist – A person who has a current Australian Health Practitioner Regulation Agency (AHPRA) Registration as an Occupational Therapist.

• Social Worker – A person who is a member of the Australian Association of Social Workers.

• Speech Pathologist – A person who is a Certified Practising Speech Pathologist as approved by Speech Pathology Australia.

• Physiotherapist – A person who has a current AHPRA Registration as a Physiotherapist.

• Psychologist – A person who has a current AHPRA Registration as a Psychologist.

• Counsellor – A person who is either a member of the Australian Counselling Association or an accredited Registrant with the Psychotherapy and Counselling Federation of Australia.

• Exercise Physiologist – A person who is an Accredited exercise physiologist with Exercise and Sports Science Australia.

• Other Professional – A person who is not one of the types of professionals listed above but who has a Bachelor's degree or higher in their relevant area and holds current registration or membership with their relevant registration and or professional body.

• Early Childhood Supports - Therapy Assistant - Level 1

Support must be delivered by a therapy assistant working under the delegation and direct supervision at all times of a therapist.

• Early Childhood Supports - Therapy Assistant - Level 2

Support must be delivered by a therapy assistant working under the delegation and supervision of a therapist, where the therapist is satisfied that the therapy assistant is able to work independently without direct supervision at all times.

Note: Where a support is delivered by a therapy assistant, the therapy assistant must be covered by the professional indemnity insurance of the supervising therapist (or the therapist's or therapy assistant's employing provider).

Qualifications and Registration Groups for supports provided to those over 7 years of age:

The below listed therapies are expected to be delivered in line with the NDIS Commission’s NDIS Practice Standards and can be delivered to participants over the age of 7.

• Dietitian – A person who is an Accredited Practising Dietitian with the Dietitians Association of Australia.

• Occupational Therapist – A person who has a current Australian Health Practitioner Regulation Agency (AHPRA) Registration as an Occupational Therapist.

• Physiotherapist – A person who has a current AHPRA Registration as a Physiotherapist.

• Podiatrist – A person who has a current AHPRA Registration as a Podiatrist.

• Psychologist – A person who has a current AHPRA Registration as a Psychologist.

• Speech Pathologist – A person who is a Certified Practising Speech Pathologist (CPSP) as approved by Speech Pathology Australia.

• Exercise Physiologist – A person who is an accredited exercise physiologist with Exercise and Sports Science Australia.

• Personal Trainer – A person who has a personal training qualification (Certificate III, IV or Diploma) in Fitness or equivalent.

• Counsellor – A person who is either a member of the Australian Counselling Association or an accredited Registrant with the Psychotherapy and Counselling Federation of Australia.

• Rehabilitation Counsellor – A person who is a member of the Australian Society of Rehabilitation Counsellors Inc. or equivalent.

• Social Worker – A person who is a member of the Australian Association of Social Workers.

• Art Therapist – A person who is a Professional Member of the Australian, New Zealand and Asian Creative Arts Therapy Association (ANZACATA).

• Music Therapist – A person who is an Active "Registered Music Therapist" with the Australian Music Therapy Association.

• Audiologist – A person who is either currently certified as an Audiology Australia Accredited Audiologist by Audiology Australia or as a Full Member as an audiologist with the Australian College of Audiology.

• Audiometrist – A person who is either a Current Full Member of the Hearing Aid Audiometrist Society of Australia or who is a Current Full Member as an audiometrist of the Australian College of Audiology.

• Orthoptist – A person currently registered with the Australian Orthoptic Board.

Early Childhood Professionals include the following types of professionals.

• Occupational Therapist – A person who has a current Australian Health Practitioner Regulation Agency (AHPRA) Registration as an Occupational Therapist.

• Social Worker – A person who is a member of the Australian Association of Social Workers.

• Speech Pathologist – A person who is a Certified Practising Speech Pathologist as approved by Speech Pathology Australia.

• Other Professional – A person who is not one of the types of professionals listed above but who the provider considers to be an appropriate professional to deliver Disability-Related Health Supports in line with the NDIS Quality and Safeguarding Commission's requirements for the Therapeutic Supports Registration Group.

If you are a participant and concerned about your providers' qualifications, you are well within your rights to ask for them. If you are Plan-Managed, you could reach out and ask for assistance, or you can contact the NDIS on 1800 800 110. If you are a provider and need clarification, you can also contact your participant's plan manager (if they manage their funding this way) or speak with the NDIS. Getting clarification if you are unsure could save you from a lot of stress later.

Taking a best practice approach, we recommend that providers list the practitioner registration numbers on their invoices. Pathways to Care do intermittently check practitioner details on the appropriate registration websites to assist in monitoring compliance, supporting participants to safeguard their funding.

Call us on 1300 467 284 if you have any questions about a topic in this blog!