SaH allied health price policy ‘must be revised’
The system must acknowledge and appropriately fund all essential clinical components of allied health services, including non-face-to-face work, writes Scott Lynch.
A critical flaw lies within the Guidance for setting Support at Home prices fact sheet published by the Department of Health, Disability and Ageing two months ago. Specifically, the policy regarding how allied health services are to be billed is, frankly, untenable and threatens the very quality of care we strive to provide.
The guidance states: “For all services other than care management, transport and meal delivery, a billable unit of service will be time based, and will be the face-to-face time (or time spent on a telehealth appointment, if appropriate) spent with a participant”.
This narrow definition of billable work fundamentally misunderstands the nature of comprehensive, evidence-based allied health care in the community.
Many crucial clinical activities undertaken by allied health professionals do not occur face-to-face with a participant yet are indispensable for effective and safe care. Consider the common examples below.
- A physiotherapist developing a tailored therapy program that an allied health assistant (AHA) will then implement. This planning phase is critical for ensuring the program’s effectiveness and safety. It is also mandatory for appropriate delegation under AHA delegation frameworks.
- A speech pathologist meticulously developing a communication therapy program and a complex mealtime management plan for someone with swallowing difficulties. These are highly skilled tasks requiring clinical expertise.
- A dietitian analysing a participant’s detailed nutritional needs and developing a personalised meal plan to address specific health conditions.
- An occupational therapist completing a complex assistive technology prescription or designing home modifications to ensure a participant can live safely and independently at home.
These non-face-to-face tasks are not administrative add-ons; they are core clinical work, demanding professional skill, time, and adherence to evidence-based practice. To expect providers to roll the costs of this essential work into a purely face-to-face unit price is structurally impossible as some participants require non-face-to-face activities and others do not. It would therefore be unethical to roll this into all face-to-face visits like travel.
Other funding schemes where health professionals care for people living with complex medical conditions and disabilities including state and territory workers’ compensation and compulsory third-party cover schemes, lifetime care and support, Department of Veterans’ Affairs and the National Disability Insurance Scheme all recognise non-face-to-face clinical tasks.
If the guidance for Support at Home is not updated, it forces a grim choice: either compromise the quality of care by cutting corners on vital preparatory and follow-up work or risk the financial viability of the service.
The challenges are compounded by the requirement to roll travel costs into the same unit pricing. This is particularly burdensome for providers in regional and remote areas where travel times and costs are highly variable and often substantial.
While the Modified Monash Model offers a potential framework for structuring travel pricing to manage this variability, the current approach of simply bundling it into the face-to-face unit pricing will inevitably lead to complex administrative workarounds or, worse, render services unviable in many areas. This could create service deserts, directly contradicting the aim of equitable access to care. The NDIS, in contrast, recognises the necessity of non-face-to-face clinical work and allows for separate billing for travel, offering a more transparent and sustainable model. The Support at Home policy’s divergence on this front is puzzling and detrimental.
Ultimately, the inability to bill for essential non-face-to-face clinical services under the proposed Support at Home pricing structure indicates a concerning misunderstanding by the Department of Health, Disability and Ageing of what evidence-based allied health care truly involves in a community setting.
For the Support at Home program to genuinely succeed and meet the needs of older Australians, this policy must be revised. We need a system that acknowledges and appropriately funds all essential clinical components of allied health services, including non-face-to-face work. Furthermore, a fair and transparent mechanism for addressing travel costs, especially for regional and remote services, is crucial.
With respect to non-face-to-face services for allied health, the guidance should be updated to read: “Allied Health activities may be delivered directly (i.e., a face-to-face visit or telehealth consultation) or indirectly (i.e., completing a specific activity relating to a participant’s care, assistive technology or home modification needs without their direct involvement).”
Without these changes, we risk a system that inadvertently compromises care quality, threatens provider sustainability, and fails to deliver the person-centred, effective support that older Australians deserve. It is time for a common-sense approach that values the entirety of allied health expertise.
Scott Lynch is the founder and managing director of Community Therapy – a mobile allied health service across the Central Coast and Hunter New England region of New South Wales
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