Submission

Inclusive

Communities Fund

Consultation

Date: 31st August

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Our Commitment to First Nations Wellbeing, Culture, and Self-Determination

We stand in strong support of First Nations Australians, affirming their inherent right to self-determination, cultural preservation, and sovereignty over their land and traditions. We acknowledge that for First Nations peoples, mental health is inseparable from cultural, emotional, physical, and spiritual wellbeing—a holistic understanding maintained through thousands of years of continuous culture.

The Gayaa Dhuwi (Proud Spirit) Declaration Framework and Implementation Plan, launched in Meanjin/Magandjin (Brisbane) on the lands of the Turrbal and Jagera/Yuggera peoples where our office stands, provides a crucial 10-year roadmap.1 QAMH fully endorses this community-led approach to integrating First Nations leadership, cultural knowledge systems, and healing practices into Australia’s mental health frameworks.

QAMH is committed to supporting truth-telling as a process of acknowledging the histories, lived experiences, and ongoing strengths of First Nations peoples, particularly in the context of mental health. By confronting the impacts of colonisation, intergenerational trauma, and ongoing systemic injustices, we can better address the historical and contemporary factors affecting the mental wellbeing of First Nations individuals and communities.

In this submission, we emphasise the importance of holistic and healing approaches to mental health that incorporate the cultural knowledges, connection to Country, and spiritual practices of First Nations peoples. We are dedicated to ensuring that the principles of self-determination, cultural safety, truth-telling, and holistic health are central to the mental health initiatives and recommendations we propose. Our goal is to help build a future where mental health systems respect and respond to the unique needs and strengths of First Nations Australians.

Acknowledgement of Country

QAMH acknowledges and pays deep respect to Aboriginal and Torres Strait Islander peoples as the Traditional Custodians of the lands and waters across Australia. We honour their Elders past and present, whose knowledge, leadership, and cultural practices have sustained these lands for millennia.

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Who is QAMH?

The Queensland Alliance for Mental Health (QAMH) is the peak body for community-based mental health and wellbeing services delivered by non-government organisations (NGOs) in Queensland. We represent more than 146 members and stakeholders, involved in the delivery of these services.

Our purpose is to strengthen, promote, and advocate for community-based mental health and wellbeing service delivery for all Queenslanders, through direct engagement with our members, collaboration with government and statutory bodies, and active participation in policy reform at state and national levels.

QAMH maintains a formal collaboration with Community Mental Health Australia and contributes to the work of Mental Health Australia. We also work with both the National and Queensland Mental Health Commissions.

Our membership gives us direct insight into the experience of people living with mental health challenges, their families, carers, and kin, and the organisations that support them.

Recognition of Lived and Living Experience and Expertise

QAMH honours and affirms the lived and living experience of those who have experienced mental health and wellbeing challenges, suicide, and Alcohol and Other Drug use, and the essential contributions they make to the community mental health sector. We equally recognise the lived and living experience of family, carers, and kin, acknowledging their unique perspectives and contributions.

We acknowledge the courage and strength of those who bring their Lived and Living Expertise into professional spaces and affirm that expertise as an essential foundation for a responsive, effective, and human-centred sector.

Throughout this submission, we use the term “lived and living experience” to reflect that mental health challenges are often ongoing rather than historical, and “Lived and Living Expertise” where we refer to the knowledge, skills and insights that people develop through that experience. Both terms recognise that experiential knowledge is a genuine and valuable form of expertise, not simply a personal characteristic.

QAMH Contact Details

For any further information please contact:

Chloe Jesson
Deputy Chief Executive Officer
109 Logan Road, Woolloongabba QLD 4102
Email: clesson@gamh.org.au | Web: www.gamh.org.au

Definitions

Psychosocial disability refers to the functional effects and barriers a person may experience because of mental health challenges. These effects may be episodic or fluctuate over time and can affect participation, relationships, communication and daily life.

Psychosocial supports are non-clinical, trauma-informed, recovery-oriented services that support people experiencing mental health challenges to live independently and safely in the community. They enable people to stay well, avoid crisis and participate in community life. By strengthening wellbeing and social participation, they also reduce pressure on hospitals and emergency services, making them a cornerstone of a sustainable mental health system.2

Foundational Supports are disability supports intended to be available outside individual National Disability Insurance Scheme (NDIS) plans, including for people with disability who are not eligible for the NDIS.

Community-Based Mental Health Services delivered by the NGO sector occupy a unique and critical position within the broader mental health system. These services address the complex realities of distress shaped by trauma, poverty, isolation and other social determinants, providing practical support with housing, relationships, employment and social inclusion. These services are critical for:

• People who are eligible for the NDIS and those who are not
• Individuals facing barriers to accessing mainstream mental health services
• People whose needs are significant but not primarily clinical.

Introduction

QAMH supports the aim of the Inclusive Communities Fund (the Fund) to enable people with disability to participate meaningfully in community life.3 Building the capability of community organisations can help address exclusion and create more welcoming opportunities for connection and belonging.

However, the Fund’s design must explicitly recognise people experiencing psychosocial disability. It must also distinguish between making a community activity more inclusive and providing the flexible, relational support some people need to take part and remain connected.

A person’s capacity to participate may fluctuate over time, and the barriers they experience may not be visible. Community organisations and community-based mental health organisations have different but complementary roles in enabling meaningful participation.

The Fund is also being introduced alongside significant changes to individually funded NDIS social and community participation supports. Funding mainstream organisations to improve their capability cannot replace individually funded, participant-directed support or meet the substantial unmet need for community-based psychosocial support outside the NDIS. The

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Fund should not be used to justify reductions to individual NDIS supports or as evidence that the Foundational Supports gap has been addressed.

This submission focuses on how the Fund can recognise and respond to psychosocial disability through its guidance, partnerships, funded activities and implementation.

Summary of Recommendations

QAMH supports the Fund’s aim of building more welcoming and accessible community organisations. To work for people experiencing psychosocial disability, the Fund must explicitly recognise psychosocial disability, invest in genuine partnerships and maintain clear boundaries around what organisational capability-building can achieve. QAMH recommends that the Fund:

1. Provide the expertise and resources needed for inclusion. Explicitly name psychosocial disability in the Fund’s guidance and assessment criteria and properly fund the involvement of disability-led organisations, people with Lived and Living Expertise and community-based mental health organisations. Approaches for Aboriginal and Torres Strait Islander communities must be led by those communities and community-controlled organisations.
2. Fund practical organisational change. Support co-designed training, expert advice, accessibility reviews, inclusive policies and procedures, partnership development and small accessibility changes.
3. Support councils to make their community facilities more inclusive, identify community assets and convene local partnerships, particularly in regional, rural and remote communities.
4. Embed and evaluate lasting inclusion. Require funded organisations to embed inclusive practices beyond the grant period, properly resource continuing specialist contributions, and publicly report the Fund’s reach and outcomes for people experiencing psychosocial disability.

QAMH also emphasises that the Fund does not address unmet need for psychosocial support outside the NDIS and must not be presented as though it does.

1. What support, resources or changes would help organisations become more inclusive and accessible for people with disability?

The consultation paper recognises the importance of addressing “attitudinal barriers, not just physical barriers”. However, it does not explicitly identify psychosocial disability or mental health challenges in its discussion of barriers, inclusive practice or possible uses of the Fund.

This omission needs to be addressed. The Independent Review of the NDIS found that participants with psychosocial disability continued to experience lower community participation than other NDIS participants.4 It also heard that the National Disability Insurance Agency (NDIA) and its partners did not have a good understanding of psychosocial disability and that some NDIS processes were traumatising.4 Although the

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Fund is separate from individual NDIS supports, its design should respond to these findings and avoid another general approach in which psychosocial disability is poorly understood or overlooked.

Barriers to participation can include stigma, distress in unfamiliar social environments, fluctuations in capacity, inflexible attendance expectations, previous experiences of exclusion4 and overwhelming sensory environments.5 People may also need to step away from an activity during a period of distress and return when they are ready, without judgement or penalty.

The Fund’s guidelines, assessment criteria and practical examples should explicitly name psychosocial disability and mental health challenges. Examples of inclusive practice could include:

• flexible attendance and participation
• welcoming re-entry following time away
• clear information about what an activity involves
• opportunities to visit or meet organisers before participating
• trauma-informed responses from staff and volunteers
• approaches that reduce stigma and avoid unnecessary disclosure
• flexibility in how people communicate, engage and contribute.

The consultation paper identifies disability inclusion training as a possible use of funding. This training should be evidence based, trauma-informed and recovery-oriented, with content specific to psychosocial disability and mental health challenges. Generic disability-awareness training may improve general understanding, but it cannot be assumed to equip staff and volunteers to respond appropriately to episodic and fluctuating needs, distress, trauma, stigma, disclosure and relational safety.

People with Lived and Living Expertise of psychosocial disability should be meaningfully involved in designing and delivering training, developing assessment criteria, assessing grant applications and evaluating the Fund. They should be properly remunerated for this work.

Partnering with disability-led organisations

The consultation paper proposes funding expert advice, staff training and lasting partnerships between community organisations and disability organisations. Community-based mental health organisations should be explicitly recognised as potential expert partners in this work.

Disability-led organisations, people with Lived and Living Expertise and community-based mental health organisations bring different but complementary expertise. The Fund should support partnerships that draw on these contributions and properly resource each partner’s involvement.

Community-based mental health organisations hold specialist knowledge of psychosocial disability, recovery-oriented and trauma-informed practice, relational support and community connection. They can help community organisations understand less visible barriers, address stigma and develop participation arrangements that are flexible and welcoming.

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Many community-based mental health organisations do not deliver NDIS supports. Some deliver a combination of NDIS-funded supports and broader community mental health programs or activities. The consultation paper indicates that the Fund is not expected to pay for direct service delivery and that NDIS providers will generally not be eligible for funding. QAMH is not seeking to change this boundary. However, the guidelines should clarify that delivering some NDIS supports does not automatically prevent an organisation from contributing as a funded expert partner or seeking funding for a separate community activity that meets the Fund’s purpose.

Eligibility should be determined by the proposed activity and its alignment with the Fund’s purpose, rather than an organisation’s funding mix alone. The guidelines should clearly distinguish between direct NDIS service delivery, which the Fund does not intend to support, and the broader expertise and community activities of organisations that also deliver some NDIS supports.

Effective partnerships require time, coordination and specialist expertise. The Fund should not assume that community-based mental health organisations or people with Lived and Living Expertise can provide this work through existing resources or goodwill. Funding should cover the real costs of:

• properly remunerated Lived and Living Expertise
• specialist advice and workforce development
• relationship and partnership development
• coordination between partner organisations
• locally designed approaches that respond to community needs.

For Aboriginal and Torres Strait Islander communities, funded approaches should be grounded in self-determination, cultural safety, social and emotional wellbeing and holistic understandings of health.1 Aboriginal and Torres Strait Islander communities and community-controlled organisations should lead their design and delivery.

Recommendations

• Ensure the Fund explicitly includes people experiencing psychosocial disability by naming psychosocial disability and mental health challenges in its guidance, assessment criteria, funded training and evaluation.
• Embed Lived and Living Expertise of psychosocial disability throughout the Fund, including in its co-design, training development and delivery, grant assessment and evaluation, with people properly remunerated for their contribution.
• Recognise community-based mental health organisations as eligible expert partners and clarify that eligibility is determined by the proposed activity, rather than whether an organisation receives any NDIS funding.
• Fund the full costs of specialist advice, Lived and Living Expertise, partnership development and coordination, rather than relying on goodwill.
• Ensure approaches for Aboriginal and Torres Strait Islander communities are led by Aboriginal and Torres Strait Islander communities and community-controlled organisations.

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2. What activities should the Fund support, given that it will not pay for service delivery?

Within the Fund’s boundary of not paying for direct service delivery, QAMH supports funding for:

1. co-designed psychosocial disability training for staff and volunteers
2. expert reviews of organisational policies, communications and participation arrangements
3. development of practical tools, induction materials and inclusive procedures
4. partnership development and coordination to support people with psychosocial disability to participate meaningfully in community life
5. small changes that address psychosocial and sensory barriers
6. evaluation of changes in organisational practice and participation.

Making a community activity more inclusive, however, does not mean that every person will be able to participate without individual support. Some people experiencing psychosocial disability need flexible and relational assistance to:

• identify activities that reflect their interests
• build confidence to enter an unfamiliar setting
• navigate social and practical barriers to participation
• respond to fluctuations in their needs
• develop relationships and remain connected over time.

This support enables people to exercise genuine choice and control over how, where and with whom they participate. Without it, people may be limited to activities they can access independently or directed towards whichever activities are available, regardless of whether they are suitable. An activity can be inclusive in its design while remaining inaccessible to someone who does not have the support needed to take part.

The consultation paper makes clear that the Fund will build the capability of community organisations and will not pay for direct service delivery. The Fund can therefore improve what community organisations offer, but it cannot provide the individual support some people need to access those opportunities. This boundary should be clearly reflected in the Fund’s design, public description and evaluation. This distinction is particularly important because the Fund has been announced alongside reductions to individually funded NDIS Social, Civic and Community Participation and Capacity Building Daily Activity supports. QAMH acknowledges that these changes are outside the scope of this consultation and will be considered through separate processes.

These reforms have different purposes. The Fund can improve the inclusiveness of community organisations, while participant-directed support enables people to access and sustain participation in ways that respond to their individual needs.

Recommendations

• Support co-designed training, expert advice, accessibility reviews, inclusive policies and procedures, partnership development and small accessibility changes that respond to psychosocial disability.

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• Design, describe and evaluate the Fund as a complement to, not a substitute for, individually funded and participant-directed support. The Fund’s outcomes should not be used as evidence that people no longer require flexible individual assistance to participate in community life.

3. What role could local governments play in supporting community inclusion?

Effective local collaboration requires flexible funding, dedicated resources and meaningful involvement by relevant organisations in planning and shared decision-making. This is consistent with the Productivity Commission’s finding that collaborative place-based approaches can respond to local needs, reduce fragmentation and address service gaps.6 These principles are particularly important in regional, rural and remote Queensland, where thin markets, workforce shortages, travel distances and limited community infrastructure can restrict access to specialist partners.

QAMH’s 2025 Regional, Rural and Remote Roadshow highlighted the contribution local activities make to community connection.7 Attendees identified grassroots fishing and mentoring groups that build confidence and social connection, art expos that foster connection and belonging, and wellness expos and meet-and-greets that strengthen trust. The Roadshow also found that the closure of BikeSheds and other short-term youth initiatives in Cairns had left many children and young people without safe spaces, mentoring or diversionary activities.7

The Fund should support flexible, locally determined approaches. Application and reporting requirements should also be proportionate for small and medium-sized organisations, as excessive administrative costs can reduce service availability and choice, particularly in thin markets.6 Social prescribing provides a useful framework for considering the role of local government. It connects people with non-clinical community activities that reflect their needs and interests but depends on suitable and welcoming community opportunities being available and known.

A national feasibility study commissioned by the Australian Government Department of Health and Aged Care found that limited capacity in community organisations can leave social prescribing as a “road-to-nowhere” for people referred to it.8 The study also highlighted young people at risk of poor mental health as a group for whom social prescribing could offer crucial early intervention.8 The Fund’s aim of building the capability of community organisations speaks directly to this problem. Without inclusive, welcoming and well-resourced community groups, social prescribing and similar pathways are unlikely to deliver meaningful participation for people experiencing psychosocial disability.

Local governments could contribute to the Fund in two distinct but connected ways: by making the community assets and activities they operate more inclusive, and by convening local partnerships. Local governments operate many of the places the Fund is intended to make more inclusive, including libraries, community centres, halls and public spaces. As eligible applicants, councils can use the Fund to improve the accessibility of these assets, strengthen inclusive practices among staff and volunteers, and support activities that build connection and belonging.

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Local governments can also act as convenors. Through their established relationships with local organisations, councils can identify community assets, bring potential partners together and connect smaller organisations with disability-led organisations, community-based mental health organisations and people with Lived and Living Expertise. This role may be particularly valuable in regional, rural and remote Queensland, where limited community infrastructure and access to specialist partners can make it difficult for individual organisations to establish partnerships independently.

The Australian Library and Information Association’s Libraries as Social Cohesion Hubs report illustrates the potential of local community assets.10 Participating libraries used trusted and accessible community spaces to deliver locally responsive programs that strengthened connection and belonging. The report also found that partnerships with community groups, organisations, businesses, individuals and council staff were important to growing connections and building trust.10

Recommendations

• Support locally determined roles for local governments to make community facilities more inclusive, identify community assets and convene partnerships, particularly in regional, rural and remote communities.
• Provide flexible funding for locally determined approaches, with proportionate application and reporting requirements and specific consideration of thin markets in regional, rural and remote communities.

4. What is the best way for community organisations to build meaningful and lasting inclusion?

The consultation paper states that projects should build relationships, belonging and meaningful community participation, rather than only support attendance.3 It also says the Fund should not recreate programs that separated people with disability from the wider community or limited their choice and control. QAMH supports these principles.

Lasting inclusion requires funded projects to embed inclusive practices in organisational policies, staff and volunteer induction, ongoing training and enduring local partnerships. However, sustainability should not mean that specialist partners or people with Lived and Living Expertise are expected to continue contributing based on goodwill and without funding.

Evaluation should measure the Fund’s reach and outcomes for people with psychosocial disability from the outset. This should include whether funded organisations have changed their practices, whether people experience genuine belonging and sustained connection, and whether people with psychosocial disability are benefiting equitably from the investment.

Recommendations

• Require funded organisations to embed inclusive practices in policies, staff and volunteer induction, ongoing training and local partnerships beyond the grant period. Sustainability should not depend on unpaid specialist contributions or goodwill.
• Monitor and publicly report the Fund’s reach and outcomes for people experiencing psychosocial disability from the outset.

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The gap the Fund does not close

Substantial unmet need for community-based psychosocial support outside the NDIS remains. The national analysis undertaken by Health Policy Analysis estimated that 493,600 Australians aged 12 to 64 had an unmet need for psychosocial support outside the NDIS in 2022–23.10 This included an estimated 92,010 Queenslanders. At the same time, NDIA data show that the proportion of access decisions for people applying with primary psychosocial disability that resulted in access being met declined from 56 per cent in 2021-22 to 31 per cent in the first half of 2025-26.11 These figures point to a significant and continuing gap between the number of people who need psychosocial support and the number able to obtain it through the NDIS or services outside the Scheme.

The Inclusive Communities Fund is directed towards the capability of mainstream community organisations. It does not fund the ongoing delivery of psychosocial support and should not be presented as though it closes this gap.

Government communications, program guidance and evaluation should clearly distinguish between:

• improving the inclusiveness of community organisations
• enabling people to obtain the individual support they need to participate
• addressing unmet need for community-based psychosocial support.

The existence of the Fund, the number of activities supported or increased participation in funded organisations must not be used as evidence that reduced NDIS supports are sufficient or that gaps in community-based psychosocial services have been addressed.

Recommendation

• State clearly that the Fund complements, rather than replaces, individually funded and participant-directed NDIS supports, Foundational Supports and community-based psychosocial services. Acknowledge that it does not address unmet need for psychosocial support outside the NDIS and must not be presented as though it does.

Conclusion

QAMH supports the Inclusive Communities Fund’s aim of creating more welcoming and accessible opportunities for participation in community life. Its design must explicitly recognise psychosocial disability and embed the expertise of people with Lived and Living Expertise and of community-based mental health organisations. This recognition must guarantee inclusion of Aboriginal and Torres Strait Islander peoples, for whom approaches must be led by Aboriginal and Torres Strait Islander communities and community-controlled organisations, and grounded in self-determination, cultural knowledge and social and emotional wellbeing.

The Fund can strengthen community organisations, but its outcomes must not be taken as evidence that participant-directed support is no longer required or that unmet need for psychosocial support has been addressed. Clear guidance, properly funded partnerships and transparent evaluation are essential. Success should be measured by whether people

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experiencing psychosocial disability have greater choice, belonging and sustained connection in their communities.

References

1 Gayaa Dhuwi (Proud Spirit) Australia. (2025). Gayaa Dhuwi (Proud Spirit) Declaration framework and implementation plan 2025–2035.

2 Flatau, P., Kaleveld, L., Callis, Z., & Kuppers, D. (2026). Capturing the economic value of psychosocial supports. Centre for Social Impact, University of Western Australia.

3 Australian Government Department of Health, Disability and Ageing. (2026). Inclusive Communities Fund consultation paper.

4 Independent Review into the National Disability Insurance Scheme. (2023). Working together to deliver the NDIS: Final report (p. 128). Australian Government.

5 Aminpour, F., Whitby, M., Haddad, S., Carnemolla, P., & Sunstrum, F. (2026). Towards neuroinclusive public open spaces: Evidence and implications from the City of Sydney. UNSW City Futures Research Centre.

6 Productivity Commission. (2025). Delivering quality care more efficiently: Interim report. Australian Government.

7 Queensland Alliance for Mental Health. (2026). QAMH 2025 regional, rural and remote insights report.

8 McNamara, S., Nichols, T., Wells, L., Morgan, M., & Calder, R. V. (2025). Social prescribing in the Australian context: A national feasibility study report. Australian Health Policy Collaboration, Victoria University, pp. 26, 37.

9 Australian Library and Information Association. (2026). Libraries as social cohesion hubs: 2025–2026 report.

10 Health Policy Analysis. (2024). Analysis of unmet need for psychosocial supports outside of the National Disability Insurance Scheme. Department of Health and Aged Care.

11 National Disability Insurance Agency. (2026). NDIS quarterly report to disability ministers: 31 December 2025. Australian Government.

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