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7.4 Approving and Reviewing Household Services decisions
Determinations for household services
For MRCA clients, a determination to pay compensation for household services is made under section 214 of MRCA using the criteria specified in section 215. Consistent with the consideration and determination process specified under section 333 of MRCA, the determination must be made in writing, after all matters relevant to the claim have been considered.
For DRCA clients, a determination to pay compensation for household services is made under subsection 29(2) of DRCA and must be made in writing. DRCA clients with eligibility under the 1930 Act or 1971 Act may be assessed for household services through section 124(5) of the DRCA. Their eligibility applies from 1 December 1988 (through the transitional provisions), which is the date of the commencement of the DRCA.
A determination to approve or deny compensation for household services may be made by a delegate of the MRCC at the APS 5 level or above.
In all cases, a formal determination must be sent to the client whenever a decision is made to approve or extend a household services approval, or reject the claim. The determination letter must address all matters relevant to the claim and clearly explain the reasons for the determination and the issues that have been considered. Issues that must be considered are outlined in section 7.2 of this Guide.
The determination provides the legislative authority for services to be paid. Without a current determination in place, invoices for services cannot be legally paid.
A determination to approve or deny compensation for household services is a reviewable decision and clients must be provided with their appeal rights in the determination letter.
It is mandatory that R&C ISH standard letters are used when communicating with clients about their household services. Letters generated from R&C ISH will automatically attach to the client’s UIN folder in TRIM.
Approved period for household services
Delegates should not make open-ended determinations for the provision of household services and all determinations must have a start date and an end date. All new claims and renewals that are approved should be for a period of five (5) years. The exception to this is if the client is diagnosed with a degenerative condition with rapid progression; there are extenuating circumstances, such as a change in the client's informal care and support striuctures; or that the claim is a short term request for support after surgery/ hospitalisation. An ADL assessment must be conducted for every new claim and renewal unless it falls into the emergency/ extenuating circumstances described above.
Periodic, but irregular services, such as pool cleaning, must also be included in the approval determination. For example, a client may be able to manage pool cleaning themselves using a creepy crawly however, at times the chemicals in the pool may become unbalanced and the pool becomes unsafe to swim in. In such a case, the pool cleaning approval must document the frequency of the service and the cost of each service. For example, “pool cleaning is approved up to 3 times per year, at a cost of $ per service”. This prevents the client from having to submit quotes each time the pool cleaning is required.
Approved hours and amounts for household services
It is mandatory that R&C ISH standard letters are used when communicating with clients about their household services. Using these letters will also ensure the hours and amounts for household services are appropriately communicated to clients.
Approved hours and amounts for household services must be based on evidence from the household services assessment, and/or information from the client’s treating health professional and/or the client’s rehabilitation provider. Reviewing evidence from all sources will ensure that a whole-of-person approach is utilised.
Where a client is residing in a rural or remote location, and there are a limited number of providers in their location, it is likely that a service provider may need to travel some distance in order to deliver household services to the client. In these cases, it is entirely reasonable for providers to include travel costs in their quotes and clients should not be disadvantaged because of their location. It is the role of the Rehabilitation Coordinator to determine whether these quotes are reasonable and to ensure that any approval of services are within the statutory limit. The DVA website provides information on the travel for treatment rates.
Rehabilitation Coordinators must not approve household services in excess of the legislated statutory limits. Details of the maximum limits are available in the current payment rates chart in the CLIK Compensation and Support reference library. The MRCA limit is listed on the MRCA Rates and Allowances page. The DRCA limit is listed on the DRCA and Defence Act payments page.
Where there are difficulties in meeting a client's household service needs within the statutory limits, and the client's conditions are such that they are likely to also require nursing care and attendant care services, Rehabilitation Coordinators must contact the Community Nursing Program with a ‘cc’ to the Rehabilitation Policy Team to discuss the need for an assessment. A Clinical Nurse Consultant recommended by DVA's Community Nursing Program will be utilised to conduct a detailed assessment of the person's needs and make recommendations about the type and level of services that they require. This will ensure that an appropriate level of services can be provided to meet the client's assessed needs, in line with the legislation and the Department's usual contractual arrangements.
Renewing household services
Rehabilitation Coordinators are expected to ensure that the determination letter approving household services clearly communicates:
- the date when the determination expires;
- the client’s responsibility to contact the Department in plenty of time if they require household services after the expiry date; and
- that any invoices received after the expiry date cannot be paid by the Department, and will be the financial responsibility of the client.
Clients have the responsibility for managing their household services including renewing services before the approval period expires, returning claim forms on time and liaising with providers. This approach is to encourage self-management as much as possible. However, clients must be provided with every opportunity to renew their services prior to the end of the approval period and a claim form is to be sent to clients one month prior to the expiration of the approval period.
Rehabilitation Coordinators will be prompted by R&C ISH to provide clients with renewal forms, at least one month prior to expiration of the current determination.
If a client is not provided with information about renewing their services prior to the end of the approval period and the Rehabilitation Coordinator is aware that they are likely to continue to require household services, an interim determination will need to be drafted. The determination provides the legislative authority for services to be paid and without a current determination in place, invoices for services cannot be legally paid. An interim determination will enable services to be provided for a specified period, until the client is able to return the renewal forms.
Proactive case management is required to ensure that a client is not sent information about renewing services unnecessarily, if they have already contacted the Department themselves to activate the approval process. R&C ISH processing is expected to assist with managing household services cases.
All household services renewals require a new ADL assessment to be completed.
Please refer to section 7.3 of the Rehabilitation Policy Library for further information about value for money with household services.
Reviewing household services
In some circumstances, including at the clients request, it may be necessary to review a person's need for household services during the approval period. This may occur, for example, where a client requests an increase in services due to the worsening of their accepted condition, or the person's children who were undertaking certain household tasks move out of home. In these situations, it will be necessary for the delegate to request an ADL assessment to determine whether a change in the level of household services is reasonably required.
Where clients have high care needs, Rehabilitation Coordinators may need to liaise with the rehabilitation policy section, to consider whether this review may be able to be done as a file review without the need to contact the person, or if the assessment should be done in conjunction with another area within DVA such as Community Nursing or VHC. This decision to undertake a joint assessment will be based on the individual circumstances of the client, and the range of services they are receiving through DVA.
Decision to cease or reduce household services
Delegates have the discretion to consider that household services continue to be reasonably required for a grace period after a change in a client’s circumstances. As a general principle, 28 days is considered a reasonable grace period, before the decision to reduce or cease the level of approved household services takes effect.
Household service can therefore continue for a period of 28 days from:
- the date of death of a client; or
- the date a client moves into residential care on a permanent basis; or
- the date a client is advised that household services will be reduced or ceased altogether because of a change in their circumstances.
This provides a fair opportunity for adjustment to service arrangements, or for a client to submit further evidence in support of their claim.
Household services and the National Disability Insurance Scheme (NDIS)
Household services can be provided by both DVA, through a specific services plan, or by the NDIS, through an individual care plan. Where DVA clients are receiving support through the NDIS, they can choose which of these options suit them best. However, an important principle is that the same household services must not be provided by both NDIS and DVA.