Community Visitor Scheme Consultation
Submission to the Department of Health, Disability and Ageing

12 September 2025

Sent via email: CVSproject@wheretoresearch.com.au

We thank the Department of Health, Disability and Ageing (the Department) for the opportunity to provide a submission on the development of a nationally consistent Community Visitor Scheme (CVS), which is of considerable importance to our communities.

Inclusion Australia is the peak national body representing people with an intellectual disability and their families, with member organisations in each state and territory. We are delighted to make the following submission with Down Syndrome Australia, who leads a consortium representing people with intellectual disability and their families and supporters with a focus on intellectual disability caused by chromosomal variations. Please see page 4 for more information about our organisations.

We strongly support a nationally consistent approach to CVS in line with the Recommendations of the Disability Royal Commission. This must build on existing local expertise, connect into independent advocacy and other important community-led informal supports, and be sustainably resourced to match true community need – for people with disability within and outside the NDIS.

The Discussion Paper rightly situates the development and strengthening of independent oversight mechanisms, including CVS, as part of the broader disability rights movement throughout the twentieth century. Independent oversight and safeguarding, including the provision of informal safeguards, is essential to Australia’s international human rights obligations, particularly Article 16 of the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), which provides that:

In order to prevent the occurrence of all forms of exploitation, violence and abuse, States parties shall ensure that all facilities and programmes designed to serve persons with disabilities are effectively monitored by independent authorities.1

The Disability Royal Commission unequivocally showed that experiences of violence, abuse, neglect, and exploitation are frequently and disproportionately experienced by people with an intellectual disability,2 largely because those experiences are more likely to (though do not solely) take place in segregated

— footnotes at bottom — 1 United Nations Convention on the Rights of Persons with Disabilities. 2006. United Nations Human Rights Office of the High Commissioner. Retrieved from: https://www.ohchr.org/en/instruments-mechanisms/instruments/convention-rights-persons-disabilities 2 Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. 2023. Executive Summary: Our vision for an inclusive Australia and Recommendations. Retrieved from: https://disability.royalcommission.gov.au/system/files/2023-09/Final%20Report%20-%20Executive%20Summary%2C%20Our%20vision%20for%20an%20inclusive%20Australia%20and%20Recommendations.pdf., p. 84-85.

settings, separate from the broader community.3 People with an intellectual disability, including people with complex needs, are much more likely to experience life in such settings.4

A snapshot of evidence drawn from the findings of the Disability Royal Commission produced by Inclusion Australia, attached at the end of this letter, demonstrates the ways experiences of violence, abuse, neglect and exploitation significantly and disproportionately impact our community.

For this reason, strong safeguards are critical – and these safeguards must extend beyond formal oversight alone. Informal supports,5 peer networks, advocacy organisations, and other community-led initiatives all play an equally vital role in preventing harm and protecting rights. CVS is one important part of this, but it cannot stand alone. A sustainable and effective safeguarding system requires governments to invest in multiple, interconnected community-level mechanisms that provide both formal and informal oversight, support people to build informal supports in their lives, and enable people to raise concerns safely.

CVS as part of a broader network of connected formal and informal safeguarding

We believe a nationally consistent, well-resourced CVS – strongly connected to independent advocacy – is essential. However, CVS is only one component of a much broader community-level model of safeguarding that needs to be invested in to build the informal supports in the lives of people who are experiencing very high levels of social isolation, and who are therefore at elevated risk of violence, abuse, neglect and exploitation.

To be effective, CVS must be embedded within a wider ecosystem that includes both formal and community-based or informal supports, including:

Independent advocacy that can act quickly when risks are identified.
Peer-led initiatives that build trust and empower people with intellectual disability to speak up. Including programs led by people with disability, such as the VALID8 model discussed below.
Community development approaches that strengthen informal networks of support, for example, citizen advocacy services, which connect vulnerable people with disability with a community volunteer who advocates for the person in a very long-term unpaid relationship, and Self Advocacy groups that teach people about their rights.

Formal bodies who have legislated powers in their jurisdiction to investigate reports of abuse of people with disability. These approaches are interconnected and mutually reinforcing. Without investment across these different approaches, CVS in its current form will not be sufficient to address the systemic risks of violence, abuse, neglect and exploitation highlighted by the Disability Royal Commission. Governments must recognise the need for this broader network of community-led initiatives alongside a nationally consistent CVS to create a truly robust safeguarding framework.

Learning from the VALID8 model

The VALID8 tool, developed by our Victorian member organisation VALID, was funded by the Victorian Government as part of the transition from government-run disability services. It started as a self-audit for disability services, particularly group homes, and is designed to help these services learn whether they were doing what they could to empower people with intellectual disability to live their own lives. It was also a way services could define and develop best practice to help empower people they support.

— footnotes at bottom — 3 McVilly, K., Ainsworth, S., Graham, L., Harrison, M., Sojo, V., Spivakovsky, C., Gale, L., Genat, A., Zirnsak, T. (2022). Outcomes associated with ‘inclusive’, ‘segregated’ and ‘integrated’ settings: Accommodation and community living, employment and education. A research report commissioned by the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. University of Melbourne, Australia. 4 McVilly, K. et al. 2022. Outcomes associated with ‘inclusive’, ‘segregated’ and ‘integrated’ settings. 5 The Disability Royal Commission described informal safeguards as “…the social support networks that provide protection for people with disability by increasing connections, relationships and visibility in the wider community. Informal supports complement formal safeguards and are a preventative measure against the risks of violence, abuse, neglect and exploitation. Enabling and supporting interpersonal relationships is an integral component to building an inclusive Australia”

The VALID8 program has demonstrated success in gaining the trust of people with an intellectual disability in services and facilitating meaningful disclosures about service quality and safety concerns. This peer-to-peer approach creates safe spaces for honest feedback that traditional quality review processes often fail to capture.

This approach recognises that people with an intellectual disability bring unique expertise to quality review processes, including by understanding the lived experience of using services, identifying barriers and issues that others might miss, and communicating with service users in ways that build trust and encourages honest feedback. Their involvement as quality reviewers also challenges assumptions about capability and demonstrates the valuable contributions people with an intellectual disability can make to service improvement.

Models like the VALID8 tool should be considered by governments as ways of embedding peer-led and disability-led approaches into safeguarding. These approaches complement formal oversight mechanisms such as CVS by creating culturally safe spaces for people with intellectual disability to share concerns, shaping service improvement by ensuring that lived experience drives quality and accountability. We are heartened to see this model is being explored for national roll-out as ACTIV8, supported through an NDIS Quality and Safeguards Commission grant.

Our recommendations

Building on Recommendations 11.12 and 11.13 of the Disability Royal Commission, we recommend the Commonwealth, together with states and territories, must:

Invest in a nationally consistent CVS, which is sustainably resourced to match true community need and prioritise those at greatest risk of violence, abuse, neglect and exploitation – including the settings in which this is most likely to occur
- CVS should remain independent from the NDIS Commission but should align with their work, including their regulatory priorities. CVS should also have powers to refer issues to the Commission or other jurisdictional regulatory bodies if more appropriate. There may be a role for the Commission to support capacity building within CVS, particularly in WA and Tasmania where a CVS would be established for the first time.
- Current CVS should remain administered through current arrangements, with sufficient funding provided by each jurisdiction to ensure comprehensive coverage by the CVS. WA and Tasmanian governments to establish schemes in their jurisdictions, through targeted community consultation and co-design.
Invest in mutually reinforcing, evidence-based and interconnected safeguarding approaches, including links with independent advocacy
- Ensure CVS is connected with independent advocacy, providing information, referral, direct advocacy, and informal safeguards for people with an intellectual disability, particularly those with complex needs or high communication support needs.
- Ensure that a range of approaches to safeguarding (including community and disability-led approaches discussed earlier) are fully resourced to build the informal supports that create trust, enable disclosure, and strengthen the capacity of people with disability and their communities to prevent, identify and respond to harm.

Inclusion Australia and Down Syndrome Australia strongly support the development of a nationally consistent CVS and welcomes the opportunity to provide input into this important work. We thank the Department again for the opportunity to contribute and would be pleased to discuss any aspects of this submission further.

About our organisations

Inclusion Australia is the national Disability Representative Organisation representing the rights and interests of people with an intellectual disability and their families. Founded more than 70 years ago, our mission is to work with people with an intellectual disability, their families and our members to make positive change.

Our strength is in our national representation and our connection to our community. We have a member organisation in every state and territory across Australia:

ACT Down Syndrome and Intellectual Disability (ACT DSID)
Council for Intellectual Disability (NSW CID)
Developmental Disability WA (DDWA)
Inclusion Northern Territory (Inclusion NT)
Parent to Parent Queensland (P2P)
South Australian Council on Intellectual Disability (SACID)
Speak Out Advocacy (Tasmania)
Victorian Advocacy League for Individuals with Disability (VALID).

Down Syndrome Australia was established in 2011 as the peak body for people with Down syndrome in Australia. Our purpose is to influence social and policy change and provide a national profile and voice for people living with Down syndrome.

Our vision is an Australia where people living with Down syndrome are valued, reach their potential, and enjoy social and economic inclusion. DSA leads a consortium of organisations to represent people with Down syndrome and similar chromosomal variations. The Consortium provides systemic advocacy for Australians with Down syndrome and similar chromosomal variations.

Lessons from the Disability Royal Commission

People with an intellectual disability are more likely to:

Live in a group home Almost half of Specialist Disability Accommodation (SDA) participants have an intellectual disability as their primary disability (42%).
Be unemployed, or work for subminimum wages People with an intellectual disability are less likely to be employed full-time than other people with disability and are more likely to be employed in an Australian Disability Enterprise, with only 15% having a job in open employment on a full wage.
Suffer from financial hardship Among people with disability, people with an intellectual disability are among the least likely to receive an income from a wage through employment and report higher rates of financial hardship.
Rely on government payments as a primary source of income 72% of people with an intellectual disability’s main source of income comes from a government pension or allowance, usually the Disability Support Pension.
Be a victim of violence and abuse 67% of people with an intellectual disability have experienced violence since the age of 15. The rate is higher among women with an intellectual disability.
Be overrepresented in the criminal justice system People with an intellectual disability, especially First Nations people, are significantly overrepresented at all stages of the criminal justice system, from police contact and arrest, through to court processes and correctional settings.
Be detained for longer periods if found unfit to stand trial When a person with an intellectual disability does not have access to appropriate supports, they are likely to be detained for longer periods than had they been found guilty and sentenced accordingly, and are at risk of being detained indefinitely.
Be subject to restrictive practices in response to ‘behaviours of concern’ People with disability are subject to the greatest use of restrictive practices in segregated settings such as group homes, where people with an intellectual disability are more likely to reside.
Be overprescribed psychotropic medications In some cases, the number and dosage levels of psychotropic medications administered to people with an intellectual disability are so significant, they constitute abuse.
Experience seclusion and solitary confinement in youth detention and prisons Isolation amounting to solitary confinement is over-used in criminal justice settings, especially youth detention, in which people with an intellectual disability are overrepresented.
Have limited access to legal aid as victims of crime People with an intellectual disability are likely to experience a range of barriers to access to justice, such as support to give evidence with proper legal representation.
Have limited access to quality healthcare People with an intellectual disability experience significant barriers in accessing safe and quality healthcare, and experience higher mortality rates, increased incidence of preventable illness and more frequent hospital admissions.