How do auditors assess Early Childhood Supports under the latest NDIS Price Guide?

I have seen a lot of posts from Allied Health professionals since the latest NDIS Price Guide came out, rightly concerned about how the changes (or lack thereof) will affect their services. But I haven't seen other auditors talk about how these changes will affect an audit. If someone else has written about this, let me know, but in the meantime, here are my thoughts.

The 50% cut to travel was the biggest shock, of course, because overall the NDIS Practice Standards is based on a person-centred model, which includes participants having choice whenever possible on where services are provided. The Early Childhood Supports Module (Module 3) doubles down on this, and is quite specific in the requirements to deliver supports in places that best suit the child and family. Let's take a look at the Inclusion clause:

a) Assessment of each child’s development focuses on the child’s functions in their everyday routines and activities in their natural learning environments. 

b) A child’s inclusive, meaningful and active participation in their family life, community life and natural environments is promoted. 

c) Each child’s inclusion through participation in daily routines in their natural learning environments is promoted.

We can see that the NDIS explicitly refers to a child's "natural environments", which as far as I know, almost never includes a therapist's office. From my experience as an NDIS auditor for the past seven years, the families I've interviewed often express how grateful they are that the therapist can come to their home. This helps the child to feel comfortable, and lets them, and the child's siblings, learn along with the child.

So, what are we going to do about this as auditors? What if families start expressing their dissatisfaction that services are no longer provided in their home? Will you give a nonconformity to the provider for this?

Also, has anyone asked the Commission what we should do?

I don't have a solution yet - I think we need to come together as audit professionals to discuss this and raise concerns with the Commission on how this can be managed in practice.

Thanks for reading,

Clarisa