With all the focus on the new NDIS price guide, the other bombshell that was dropped just before that has flown a little under the radar; I’m talking about the Section 33 changes.

If you’re not really sure what this is all about and whether there’s anything you need to be doing differently, this article will take you through the essentials.

1.       What are the Section 33 changes?

From May 19, 2025, all new plans will be structured where funding is released in ‘funding periods.’ This essentially means instead of all the funds for a 12-month plan being available straight away when a new plan is created, it will instead be split into shorter ‘funding periods.’ The length of these funding periods, and whether the funding will be split equally between each of these periods, are up to the NDIA planner’s discretion.

In general, capacity building funding is being released in 3-month periods, but there have been instances where funding has been split into monthly allocations, as well as plans where it hasn’t been split up at all and the full 12-month allocation is immediately available. So, in typical NDIA style, there is already lots of inconsistency. If funds haven’t been spent in one funding period, they will roll over until the next, until the end of the plan; at the end of the plan there’s no more roll over, they’ll just disappear.

2.       What will this mean for OTs?

This could have a big impact in terms of the delivery of our services. If our clients require services that take up a lot of hours in one hit – such as an AT application, home mods application, intensive therapy block or functional capacity assessment, there may not be enough funding available in that funding period to complete the full work required.

We can only bill for work within the funding period in which it occurs, so if the funds run out, we can’t just save up the invoices to send through in the next funding period, we just won’t get paid. This means we need to be strategic in terms of planning out our service provision to get the timing right for our clients and ourselves.

3.       What should OTs do now?

We need to start by explaining to our clients why it is essential to know the breakdown of their funding periods, including the dates and amounts. The NDIA are telling us that it is the provider’s responsibility to only provide services ‘in line with the plan’ – which means when there are funds available; the problem is, we are dependent on the participant or support coordinator sharing this information with us.

Unfortunately, the NDIA have had a lot of success with their media smear campaign and many participants are distrustful of provider intentions when we ask to see their plan (they think we want to see so we can spend all the money we can on our services). This means you’ll need to be patient and take the time to explain why we need to know this information and the risks to the client if they don’t share this. One of these risks could be that they are left to take on the responsibility of paying a bill privately if they run out of NDIA funding in a funding period, but keep requesting services.

4.       Will this impact OT service provision?

The impacts will vary depending on the funding allocation and the type of services we need to provide. We will need to be more proactive with planning our service provision; no more winging it and just providing services as they are needed. If we know someone is likely to need big items like an AT prescription, FCA, or intensive block of therapy, not just weekly capacity building, we may need to hold off commencing until enough funds roll over that we can complete the entire process in an appropriate timeframe. So, we need to know what is likely to be needed, how many hours will be needed to do it, and then explain this very clearly to our clients so that they can manage their funding appropriately. This includes remembering that many other allied health clinicians could be drawing from the same capacity building bucket; this means we need to be speaking with them too (with client permission) so they are aware why it is vital that funding is ‘saved up.’

5.       Can OTs have any impact on how funding is allocated into funding periods?

Well, yes and no. Technically it is up to the planner discretion in terms of the length of funding periods and how funding is split between the periods. If we know there is a reason for more funds to be available at the start of a plan (e.g. to allow for AT applications) or at the end of a plan (e.g. for a comprehensive FCA before the next plan review), we can include that reasoning in our recommendations section of our FCA, progress report or plan review reports. BUT, we also need to explain this reasoning to the participant and their support coordinators so they can request for these provisions to be built into the plan when they have their planning meetings. It is likely the NDIA won’t implement our suggestions for how to allocate funding unless the participant asks.

6.       Sounds like there is a risk of providers not getting paid for their services; what can we do!?

Besides being clear and patient with our communication about why it is vital to know the information about our participant’s funding periods, we need to keep on top of our own admin. This includes having systems for tracking the information about funding periods and how many hours of funding have been spent in each period. We also should move to regular billing (weekly as a minimum, but consider daily!) so that if the participant does run out of funding, we will know ASAP and only be out of pocket for one invoice instead of two or three. We can also review the wording in our service agreements to be clear that the participant will be responsible for paying the invoice if funds are not available (if this is your policy).

Hopefully this was a helpful starting point. Business owners will need to be on top of the systems we use to manage these new changes, but every OT will need to understand the changes and work within these new systems to ensure our clients get the services they need, and our OT businesses remain viable.

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