Submission on Supported Independent Living (SIL) Commissioning

Department of Health, Disability and Ageing

13 September 2026

AFDO authors and contact:

Ross Joyce
Chief Executive Officer
ross.joyce@afdo.org.au

Matthew Hall
National Manager - Systemic Advocacy & Policy
matthew.hall@afdo.org.au

Approved:

Ross Joyce
Chief Executive Officer

1. Acknowledgements
2. About AFDO
3. Acronyms and abbreviations
4. Executive summary
- 4.1 AFDO recommendations:
5. AFDO’s overall position
6. Question 1: Which SIL participants could benefit most from additional government oversight?
7. Question 2: What do high-quality SIL supports look like?
8. Question 3: How should SIL supports protect safety, health, wellbeing and rights?
9. Question 4: How can innovation improve SIL?
10. Question 5: How can participant choice and control be enhanced?
- 10.1 Funding should follow the person, not the provider contract. 17
- 10.2 Housing and support
- 10.3 Thin markets
11. Question 6: What is needed to ensure provider sustainability?
12. Conclusion

Australian Federation of Disability Organisations (AFDO) Ltd is registered as a charity with the Australian Charities and Not for profit Commission. It is also a Public Benevolent Institution, endorsed by the Australian Taxation Office as a Deductible Gift Recipient. A donation of $2.00 or more is tax deductible.

Consent to publication: Australian Federation of Disability Organisations (AFDO) consents to the publication of this submission, including the names and contact details of AFDO staff. The relevant AFDO staff also give that consent.

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1 Acknowledgements

Aboriginal and Torres Strait Islander people

Australian Federation of Disability Organisations (AFDO) acknowledges Aboriginal and Torres Strait Islander people as the First Peoples and traditional custodians of the land now called Australia. We recognise their deep and continuing connection to Country and community. We pay our respects to the traditional custodians of Country where we work, connect, or meet, which always was, and always will be, Aboriginal land. We also pay our respects to Elders past, present, and emerging.

People with disability

AFDO acknowledges people with disability in all their diversity, particularly those individuals who have experienced or are continuing to experience violence, abuse, neglect, or exploitation. We also acknowledge their families, carers, supporters, and representative organisations and express our thanks for the continuing work done by the many people supporting, protecting, and advancing the rights of people with disability.

Language used in this document

AFDO has chosen to use person-first language (like “people with disability”) in this document. Person-first language puts the person before the disability and values the individual by seeing them as a person, not a condition. This aligns with the CRPD and matches the language used by all governments in Australia. Most other Australian disability peaks also use person-first language.

We recognise many people with disability prefer identity-first language. Disability is a part of their identity and shows a connection to their community and pride in disability. Views on language reflect people’s identities, experiences of disability, and community attitudes. It is a matter of individual choice and agency. AFDO respects everyone’s right to choose how to describe their identity and experiences.

2 About AFDO

Since 2003, the Australian Federation of Disability Organisations (AFDO) has been the pre-eminent national peak for people with disability, championing their rights through our extensive member organisation network uniquely representing both disability-specific and cross-disability communities with a reach of over 4.5 million Australians.

We are, firstly, a Disabled People’s Organisation (DPO), led, governed, and predominantly staffed by people with disability. We are also a Disability Representative Organisation (DRO) funded by the Australian government. The majority of our member organisations are DPOs, family led, or specific disability not for profits. This ensures that our work is informed by lived expertise and experience, truly representing our communities.

AFDO is a strong, trusted voice for the disability sector. We advocate on national policy, inquiries, and initiatives with the Federal and state and territory governments. We work to build a community where people with disability:

have real participation in community life
can build respectful, valued relationships
participate socially and economically, and
contribute as valued citizens.

Our vision

All people with disability can take part equally in all aspects of social, economic, political, and cultural life.

Our mission

Using the strength of our member organisations to harness the collective power of uniting people with disability to change society into a community where everyone is equal.

Our strategic objectives

To represent the interests and united voice of our members and people with disability at a national and international level in all relevant forums.
To build the capacity, profile, reputation, and sustainability of AFDO through the strength of our member organisations.
To enhance the connection and influence in international disability initiatives by policy, advocacy, and engagement, focused on the Asia Pacific region.

Our members

AFDO’s member organisations contribute to the national policy agenda and address issues that impact the lives of people with disability in Australia. We understand that disability-specific organisations play a key role in the provision of information and peer support to people with disability and their families. This role keeps them closely connected to their grassroots communities. Each community has its peak organisation that uses its voice to advocate on issues.

Information about AFDO’s members can be found on our website.

Every Australian Counts

AFDO has been involved in Every Australian Counts since the beginning of the grassroots campaign that successfully advocated for the introduction of the NDIS.

AFDO continues to support Every Australian Counts by auspicing the campaign, holding a position on the Steering Committee, and providing administrative, governance, marketing and communications support.

More information about Every Australian Counts, including its current priorities and activities is available on the Every Australian Counts website.

Australian Consumers & Carers Mental Health Forum

The Australian Consumers and Carers Mental Health Forum (Forum) is a national initiative that brings together consumer and carer perspectives to develop shared positions on mental health, suicide prevention and psychosocial disability reform. The Forum supports stronger connections between mental health and disability policy and promotes collaboration across a diversity of lived experience communities.

AFDO supports the Forum by providing auspice inclusive of providing administrative, governance, marketing and communications support as well as holding a position on its Steering Committee. More information is available at The Forum.

3 Acronyms and abbreviations

This list of terms may assist users of this document to understand what we mean when we use the following terms or abbreviations.

AFDO — Australian Federation of Disability Organisations
DPO — Disabled People’s Organisation
DRC — Disability Royal Commission
DRO — Disability Representative Organisation
NDIA — National Disability Insurance Agency
NDIS — National Disability Insurance Scheme
SIL — Supported Independent Living

4 Executive summary

The Australian Federation of Disability Organisations (AFDO) welcomes the opportunity to provide input into the consultation on the future of Supported Independent Living (SIL).

This submission reflects AFDO’s role in bringing together member perspectives on the design and implementation of disability policy, including NDIS reform, housing and living supports, safeguarding, workforce, participant rights, market stewardship and the effective implementation of national disability policy.

Owing to the short timeframe for this consultation, and the significant volume of concurrent government consultation on NDIS reform and other disability policy matters requiring input from AFDO and our member organisations, AFDO has not been able to undertake a dedicated consultation process with our membership on this submission.

The positions expressed draw on AFDO’s established policy positions and the views, issues and priorities raised by members through previous consultations, forums and other engagement.

AFDO considers that further time would be required to adequately consult our membership on the detail of any proposed SIL commissioning model, and we would welcome the opportunity for further engagement as policy development progresses.

AFDO does not support commissioning as a general or default model for SIL. Commissioning should be used only as a provider-of-last-resort mechanism where there is clear evidence that no quality provider is available and other reasonable stewardship and market-development measures have failed.

AFDO has developed a series of recommendations shown below which are supported through the remainder of this submission.

4.1 AFDO recommendations:

AFDO recommends that the Australian Government adopt the following system-level approach.

Establish a national SIL market stewardship framework. Clarify the respective roles of regulation, pricing, workforce development, provider development, market intervention and commissioning, with transparent escalation criteria.

Use commissioning only as a provider-of-last-resort mechanism. Commission only where evidence demonstrates that no quality provider is available and other reasonable market interventions have failed.
Protect individualised and portable funding. Ensure funding remains attached to the participant and can move with them when an alternative quality provider is available.
Strengthen housing and support separation. Reduce structural conflicts of interest and ensure changing provider does not jeopardise tenancy.
Establish stronger provider-risk and service-quality monitoring. Use complaints, incidents, workforce indicators, restrictive practices and participant outcomes to identify provider-level risk.
Introduce a national SIL outcomes framework. Measure quality through participant-reported experience and outcomes as well as compliance data.
Strengthen independent safeguards. Fund advocacy, supported decision-making, independent monitoring and accessible external complaints and escalation pathways.
Invest in market diversity and workforce capability. Use evidence-based pricing, workforce investment and provider-development measures to support small, specialist, disability-led, culturally responsive and community-controlled providers.
Protect alternative support models. Ensure self-management, self-direction, direct employment and other individualised approaches remain available to existing and future participants.
Establish national service-continuity arrangements. Define responsibility for maintaining essential support when providers fail, withdraw or lose approval.
Require transparent implementation and evaluation. Publish the evidence supporting commissioning, independently evaluate any pilot and report publicly on participant, market, rights and cost impacts.
Embed people with disability in governance. Give people with disability, DPOs and DROs formal roles in design, implementation, monitoring and review.

5 AFDO’s overall position

AFDO supports action to improve the quality, safety, reliability and availability of SIL supports.

There are significant and longstanding systemic issues within parts of the SIL market, including:

poor and inconsistent service quality;
limited provider choice;
conflicts between housing and support provision;
workforce shortages and instability;
inadequate safeguarding and complaints responses;
provider failure and service continuity risks;
thin markets in regional, rural and remote areas;
limited access to culturally safe and disability-specific services; and
market structures that can leave participants dependent on a single provider.

These issues require stronger government stewardship, regulation and accountability.

However, AFDO does not consider commissioning to be an appropriate general response to these problems.

Commissioning should be confined to a provider-of-last-resort role where there is clear evidence that no quality provider is available to meet a person’s needs and other market stewardship interventions have failed.

The central policy challenge is therefore not simply whether government should take a more active role. Government already has important responsibilities for regulation, market stewardship, workforce development, pricing, provider oversight and service continuity.

The more important question is how government can exercise those responsibilities without reducing the rights, agency and control of people with disability.

AFDO is concerned that poorly designed commissioning could:

transfer decision-making power from participants to governments and contracted providers;
weaken the portability of individualised funding;
create closed or restricted provider markets;
increase concentration among large providers;
disadvantage smaller, specialist, disability-led and culturally responsive organisations;
entrench the connection between housing and support;
reduce opportunities for self-management, self-direction and direct employment; and
create service models driven primarily by contract efficiency rather than individual outcomes.

AFDO therefore recommends that government first strengthen the existing policy, regulatory and market settings that should support a diverse and responsive SIL market.

6 Question 1: Which SIL participants could benefit most from additional government oversight?

AFDO considers that additional oversight should be risk-based and provider-focused, not based primarily on participant characteristics or diagnostic categories.

The use of participant “cohorts” as a basis for additional intervention carries a risk that disability type, communication needs or complexity of support could become proxies for reduced autonomy.

AFDO does not support that approach.

Instead, additional oversight should be triggered by indicators such as:

persistent complaints or incidents;
restrictive practices;
poor workforce continuity;
high staff turnover;
poor governance or incident management;

conflicts between housing and support;
limited provider choice;
inability to access independent advocacy or supported decision-making;
persistent service gaps;
provider failure or withdrawal;
absence of culturally safe or disability-specific services; and
thin-market conditions.

Different disability communities may experience these risks differently.

For example, people with intellectual disability or significant communication support needs may face additional barriers to raising concerns. People with psychosocial disability may experience service instability or inappropriate assumptions about risk. Likewise, Deaf people, people with sensory disability and people who use alternative communication may face barriers if providers do not have appropriate communication capability. First Nations people with disability and culturally diverse communities may face additional barriers where culturally safe supports are unavailable.

These differences should inform how oversight and safeguards are designed, but should not be used to justify greater government or provider control over individuals.

AFDO also considers that provider performance data should play a much stronger role in determining where government intervention is required.

Poor provider performance should trigger greater scrutiny. Disability should not.

Importantly, government should distinguish between:

regulation and enforcement;
enhanced monitoring;
market stewardship;
provider development;
workforce investment; and
commissioning.

Commissioning should be the last of these tools, not the first.

7 Question 2: What do high-quality SIL supports look like?

From AFDO’s perspective, high-quality SIL must be understood as an outcomes and rights framework, not simply a provider compliance framework.

Quality SIL should enable people with disability to live ordinary lives with autonomy, safety and meaningful participation.

Key indicators should include:

Control over daily life. Participants should be able to make decisions about routines, activities, visitors, personal care and how their home is used. Support should be organised around the individual rather than the provider’s roster or operating model.

Appropriate and trusted workers. Participants should have meaningful input into the workers who support them. Workforce capability should include disability-specific knowledge, communication competence, health and behavioural support capability where required, and continuity of staffing.

Individualised support. Shared support must not result in shared lives. People living together may have different interests, routines, relationships and goals. Staffing models must be sufficiently flexible to support those differences.

Accessible decision-making. Participants must receive accessible information and appropriate supported decision-making. Providers must have the capability to communicate directly with people using their preferred communication methods.

Safety and rights. Quality must include freedom from abuse, neglect, exploitation and inappropriate restrictive practices while also protecting autonomy, dignity and the right to take reasonable risks.

Freedom to change provider. A person should be able to change provider without losing their home, essential support or continuity of care.

AFDO recommends that government develop a national SIL outcomes framework that measures these issues directly.

This should include independent participant-reported measures of:

safety;
choice and control;
workforce continuity;

communication quality;
relationships;
community participation;
ability to raise concerns;
ability to change provider; and
overall quality of life.

Provider compliance information is important, but it should not be treated as a substitute for evidence about people’s actual experiences.

8 Question 3: How should SIL supports protect safety, health, wellbeing and rights?

AFDO considers that safeguarding reform should focus on reducing structural risk, not simply increasing oversight of individuals.

The strongest safeguarding system will be one that reduces dependency, improves independent scrutiny and ensures people have realistic alternatives when services fail.

Key systemic safeguards should include:

independent advocacy;
supported decision-making;
accessible complaints mechanisms;
independent monitoring;
stronger oversight of restrictive practices;
effective worker screening and supervision;
provider-level risk monitoring;
clear escalation pathways;
rapid responses to serious incidents;
continuity planning; and
clearer separation between housing and support.

AFDO also considers that there should be stronger coordination between the NDIA, the NDIS Quality and Safeguards Commission and other relevant government agencies (including relevant agencies in the states and territories – for example, Community Visitor Schemes).

Participants should not be required to navigate jurisdictional or administrative disputes in order to resolve urgent safety concerns.

Government should also establish clearer thresholds for intervention where there is evidence of repeated complaints, poor provider governance or systemic safeguarding failures.

At the same time, safeguards must not become paternalistic or justify restricting the rights of people with disability.

A safeguarding system that increases provider control over a participant who cannot leave may increase rather than reduce risk.

9 Question 4: How can innovation improve SIL?

AFDO considers that innovation policy should focus on expanding the range of viable models available to people with disability.

The current SIL market can be overly dependent on conventional shared-support models. Government should actively support alternatives and innovative business models.

These may include:

self-management;
self-direction;
direct employment;
participant-led workforce arrangements;
individualised living options;
new approaches to shared support;
assistive technology chosen by the participant;
alternative housing and support models;
culturally specific and community-controlled services; and
locally designed approaches for thin markets.

Government should ensure that procurement and funding arrangements do not suppress innovation.

Large-scale tenders, rigid service specifications and closed panels can favour established providers and discourage smaller or emerging organisations.

AFDO therefore recommends that government assess any commissioning proposal against its impact on:

provider diversity;
disability-led innovation;
market entry;
participant-led service models;
regional supply; and
long-term competition.

Innovation should also be assessed against participant outcomes rather than savings alone.

Technology or shared staffing should not be treated as innovation where their primary effect is to reduce necessary support.

A person’s need for 24-hour support should not automatically determine the service model they must use.

10 Question 5: How can participant choice and control be enhanced?

AFDO considers that this issue should be addressed through market design as well as individual rights.

Individualised and portable funding remains fundamental. But portability alone is not sufficient if participants have no meaningful alternatives.

Government therefore has a responsibility to create the conditions in which choice can be exercised.

This requires:

sufficient provider diversity;
adequate workforce supply;

accessible information;
independent advocacy;
supported decision-making;
practical transition support;
separation of housing and support;
protection of self-management and self-direction; and
funding arrangements that allow participants to move between providers.

AFDO does not support models in which funding is effectively captured by a contracted provider.

10.1 Funding should follow the person, not the provider contract.

Nor should access to a commissioned service prevent a participant from moving to another quality provider where one becomes available.

10.2 Housing and support

The relationship between housing and support remains one of the most significant structural risks in SIL.

Where one organisation controls both, participants may face serious practical barriers to changing provider.

AFDO recommends stronger national policy settings to separate these functions wherever possible and to ensure that changing support provider does not place a person’s tenancy at risk.

10.3 Thin markets

Thin markets require active government stewardship.

However, AFDO considers that commissioning should not substitute for the systematic development of supply.

Government should first address:

pricing;

workforce shortages;
provider entry barriers;
local service development;
culturally safe provision;
disability-specific capability; and
infrastructure constraints.

Only when these measures cannot produce a quality provider should commissioning be used as a provider-of-last-resort mechanism.

11 Question 6: What is needed to ensure provider sustainability?

AFDO considers that provider sustainability should be approached through a broader market sustainability framework.

The objective should not be to preserve particular providers. It should be to ensure that people with disability have access to sustainable, high-quality and diverse supports.

Government therefore needs better information about:

the actual costs of service delivery;
workforce shortages;
provider exit;
regional costs;
specialist service capability;
market concentration;
demand and supply gaps; and
the viability of smaller and disability-specific providers.

Pricing should reflect genuine delivery costs, including workforce capability, supervision, safeguarding, participant engagement and the higher costs of service delivery in thin markets.

AFDO is concerned that large procurement exercises could unintentionally reduce sustainability by concentrating market share among a small number of organisations.

Government should avoid commissioning arrangements that:

guarantee providers’ occupancy rates;
guarantee market share;
make provider viability dependent on fixed participant numbers;
reduce incentives or create additional barriers for new providers to enter; or
create long-term regional monopolies.

Provider failure also requires a clearer national response.

AFDO recommends that government establish explicit service continuity obligations and contingency arrangements, including responsibility for ensuring participants are not left without essential support when providers withdraw or fail.

11.1 Market stewardship and system design

AFDO considers that the central issue raised by the consultation is broader than commissioning.

It is about the effectiveness of government’s stewardship of the SIL market.

A stronger stewardship framework should include:

better national and regional market data;
early identification of supply gaps;
stronger provider-performance monitoring;
improved workforce planning;
evidence-based pricing;
targeted investment in thin markets;
support for disability-led and specialist providers;
stronger housing and support separation;
clearer provider-failure arrangements; and
transparent escalation from ordinary stewardship measures to more intensive intervention.

Government should publish clear criteria explaining when each type of intervention will be used.

Commissioning should sit at the end of that escalation pathway, not at the beginning.

11.2 Implementation and transition

AFDO recommends that government develop a formal transition framework before any commissioning model is introduced.

This should ensure that:

existing quality arrangements are not unnecessarily disrupted;
participants receive accessible information;
supported decision-making is available;
independent advocacy is funded;
essential supports continue during transitions;
housing security is protected;
participants can challenge decisions;
individualised funding is maintained; and
commissioning arrangements are regularly reviewed.

No participant should be required to change a quality provider, chosen worker, funding- management arrangement or effective self-directed model merely to fit a new contract.

Any pilot should be:

voluntary wherever alternatives exist;
clearly defined;
time-limited;
independently evaluated; and
publicly reported.

Evaluation should include rights impacts, participant outcomes, market impacts, provider concentration, workforce impacts and cost.

11.3 Co-design, governance and accountability

As a Disabled People’s Organisation and national cross-disability and disability- specific peak body, AFDO considers that people with disability must have formal decision-making roles throughout this reform.

This should include people receiving SIL and people from disability communities who may experience the system differently, including:

people with intellectual disability;
people with significant communication support needs;
people with sensory disability;
people with psychosocial disability;
First Nations people with disability;
LGBTIQA+ people with disability;
culturally and linguistically diverse people with disability; and
people living in regional, rural and remote communities.

AFDO also considers that Disability Representative Organisations and DPOs should have formal roles in implementation oversight.

Co-design must begin before government settles on a preferred commissioning model.

It should continue through:

policy development;
design of safeguards;
development of procurement criteria;
implementation;
evaluation; and
ongoing review.

12 Conclusion

AFDO recognises that parts of the SIL market require significant reform.

The response should be stronger government stewardship, better regulation, improved safeguards, sustainable workforce and pricing arrangements, greater provider diversity and clearer accountability.

Commissioning may have a limited role where those mechanisms cannot secure a quality service.

It should not become a substitute for them.

AFDO supports commissioning only as a provider-of-last-resort mechanism where no quality provider is available to meet a person’s needs.

The objective of reform should be a SIL system in which government is more accountable, providers are more accountable, markets work better and people with disability have stronger, not weaker, rights, choice and control.