Submission

Commissioning approach for part of the Supported Independent Living (SIL) market

Date: 13 September, 2026

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.

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 135 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:

Dr Rosa Flaherty
Chief Executive Officer
109 Logan Road, Woolloongabba QLD 4102
Email: rflaherty@qamh.org.au | Web: www.gamh.org.au

Executive summary

Queensland Alliance for Mental Health (QAMH) supports reforms to improve the quality, safety and sustainability of Supported Independent Living (SIL). This consultation is an opportunity to ensure that any commissioning model reflects the realities of psychosocial disability and delivers better outcomes for participants.

People with psychosocial disability may experience episodic and fluctuating support needs.2 A model built around fixed programs, standardised staffing or assumptions based on diagnosis will not respond effectively. Government oversight should focus on barriers to access to SIL, identifiable risks in service arrangements, provider performance and local markets. These include limited provider choice, workforce instability, housing and support arrangements that make it difficult to change providers, and restrictive or institutional practices. Oversight must not reduce participants’ rights, privacy, choice or control.

Quality, safeguards and choice share the same foundation: a person’s ability to exercise genuine control over their home, support and relationships. SIL should be individualised, recovery-oriented, trauma-informed and culturally safe, delivered by a capable workforce and grounded in supported decision-making. Quality should be measured through outcomes that matter to participants, including autonomy, wellbeing, relationships and community participation. Reducing and eliminating restrictive practices should also be treated as an important measure of quality.

Innovation should strengthen autonomy, relationships and community participation, rather than focus primarily on technology, efficiency or reduced staffing costs. Better coordination between SIL, hospitals and community-based mental health services can prevent people inappropriately remaining in hospital. Not only do people remain in hospital because suitable community-based support is unavailable, but people are also subject to being discharged into an unsuitable arrangement because it is the first vacancy offered.

Choice must be practical. Participants should be able to influence who they live with, who supports them and how support is delivered, and to change providers without placing their housing or essential support at risk. In regional, rural and remote Queensland, investment in local workforce and provider diversity is needed to make choice genuine.

For Aboriginal and Torres Strait Islander participants, commissioning must uphold self-determination and holistic understandings of health and social and emotional wellbeing. Quality standards, safeguards and choice mechanisms should be developed with and by Aboriginal and Torres Strait Islander peoples and Aboriginal Community Controlled Health Organisations (ACCHOs).

Provider sustainability depends on NDIS pricing that covers the full cost of safe, responsive support, including proposed legislated wage increases under the Fair Work Commission’s Social, Community, Home Care and Disability Services (SCHADS) Award decision.3 Without adequate funding, smaller, specialist and community-controlled providers may leave the market, reducing continuity and choice.

QAMH’s detailed responses and consolidated recommendations set out how commissioning can deliver flexible, rights-based and sustainable SIL that enables participants to feel safe, heard, connected and at home.

Definitions

Psychosocial disability

Psychosocial disability can arise when a person experiencing mental health challenges encounters barriers that affect their ability to participate fully in everyday life. Its nature and impact may be episodic and fluctuate over time. People with the same diagnosis may have very different support needs, and a person’s needs may change with their circumstances, environment and stage of recovery.

Psychosocial supports

Psychosocial supports are non-clinical, recovery-oriented supports that help people experiencing mental health challenges live well and participate in their communities. They may assist people to build daily living skills, strengthen relationships, access education or employment, connect with their community and manage periods of increased need or distress.

A person receiving SIL may also require other psychosocial supports where these have a distinct purpose. SIL should not become a closed model in which all of a person’s support is delivered within the home.

Community-based mental health services

Community-based mental health services support people to live well in their homes and communities. Delivered by non-government organisations, these services respond to the practical and social dimensions of mental health and wellbeing, including housing, relationships, employment, social connection and participation.

The sector supports people who are eligible for the NDIS and those who are not, including people who experience barriers to mainstream services and people whose needs are significant but not primarily clinical. Community-based mental health organisations can also contribute specialist psychosocial expertise, peer support and coordination across disability, health, housing and community services.

Recovery-oriented practice

Recovery-oriented practice supports people to live meaningful, self-directed lives with hope, purpose, connection and control, whether their symptoms are ongoing. It starts from the person’s own goals rather than their diagnosis or deficits and treats recovery as a personal journey rather than a fixed clinical endpoint.

Trauma-informed practice

Trauma-informed practice recognises the widespread impact of trauma and responds in ways that promote safety, trust, choice, collaboration and empowerment. It works to avoid re-traumatisation, including through the design of physical environments, staffing and

everyday routines, and it understands behaviour as communication rather than as a problem to be managed.

Cultural safety

Cultural safety is defined by the person receiving support, not by the provider. It means an environment that is spiritually, socially, emotionally and physically safe, free of racism and discrimination, in which a person’s identity, culture and community are respected. For Aboriginal and Torres Strait Islander peoples it is inseparable from self-determination and social and emotional wellbeing.4,1

Introduction

Queensland Alliance for Mental Health supports measures to improve the quality, safety and sustainability of Supported Independent Living (SIL). Well-designed reform in this area should improve outcomes for participants, including people with the highest support needs.

Any reform must, however, be shaped by an accurate understanding of who receives SIL and why. People with psychosocial disability are a distinct part of this population, and their support needs may fluctuate as their circumstances, environment and wellbeing change. SIL arrangements must be able to respond by adjusting the timing, intensity and type of support, rather than requiring participants to fit a fixed program or shared staffing model.

A commissioning model should be judged by whether it strengthens recovery, choice, control and community connection. This reflects Australia’s obligations under Article 19 of the Convention on the Rights of Persons with Disabilities, which recognises the right of people with disability to choose where and with whom they live, on an equal basis with others, and not be obliged to live in a particular living arrangement.5 This includes supporting self-determined and culturally grounded approaches for Aboriginal and Torres Strait Islander participants. Measures of compliance, safety and risk are important, but they are not sufficient measures of quality on their own.

Commissioning must also recognise the contribution of community-based mental health organisations. Supported Independent Living does not operate in isolation. Any new model should ensure that SIL operates alongside, rather than replaces, independent psychosocial support, peer support, clinical care and opportunities for community participation.

QAMH’s responses to the six consultation questions set out what these principles should mean in practice.

Question 1: Participants

Which SIL participants could benefit most from additional government oversight of planning, delivering and monitoring of SIL supports?

Government oversight should target points of market and system failure rather than categories of participants defined by diagnosis, complexity or perceived risk. People with

psychosocial disability should not automatically be subject to greater oversight because of assumptions about their capacity, behaviour or ability to make decisions.

For people with psychosocial disability, oversight must recognise that support needs may fluctuate and that fixed staffing arrangements may not remain appropriate over time.

Additional oversight may be most beneficial where:

participants have limited access to independent advocacy, supported decision-making or trusted supporters
housing and support are closely connected, leaving participants with little practical ability to change providers without risking their home
participants in shared arrangements have limited influence over housemates, workers, routines or staffing
provider cultures or routines limit participants’ autonomy or reproduce institutional ways of living
workforce instability or provider failure creates risks to safety and continuity
regional, rural and remote markets offer few providers, limited housing options or insufficient workforce capacity
participants from culturally and linguistically diverse backgrounds have limited access to culturally safe, in-language or interpreted support.

Shared support arrangements require particular scrutiny. Staffing ratios and shared hours should not be determined primarily by provider efficiency. Oversight should examine whether these arrangements continue to meet each participant’s individual needs and preferences as their circumstances change.

For Aboriginal and Torres Strait Islander participants, the design of oversight requires particular care. It should be developed in partnership with Aboriginal and Torres Strait Islander peoples and community-controlled organisations and reflect holistic understandings of health and social and emotional wellbeing. Cultural identity must not be treated as a risk factor, and mainstream compliance models should not be applied without local leadership and cultural adaptation.

Any additional oversight must be proportionate and must not reduce participants’ rights, privacy, choice or control.

Recommendation for Question 1

Target additional oversight according to identifiable risks in service arrangements, housing and support interfaces, provider performance and local markets, rather than diagnosis or participant characteristics alone.

Questions 2, 3 and 5: How quality, safeguards and choice work together

QAMH has grouped these questions because quality, safeguards and participant choice have common foundations for people with psychosocial disability. Considering how they interact avoids repeating the same requirements under each question.

Psychosocial support needs may fluctuate. A one-size-fits-all model based on fixed routines, staffing or levels of support will not respond effectively to these changes. SIL must be flexible while maintaining trusted relationships, housing stability and community connection.

Quality, safeguards and choice are also mutually reinforcing. SIL cannot be high quality if participants lack control over their home and support. Safeguards cannot be effective without independent ways to raise concerns. Choice is not genuine if changing providers places housing or essential support at risk. Recovery-oriented, trauma-informed and culturally safe practice, supported decision-making and a capable workforce underpin all three.

For Aboriginal and Torres Strait Islander participants, these foundations must reflect self-determination and holistic understandings of health and social and emotional wellbeing.

Cross-cutting recommendation for Questions 2, 3 and 5

Co-design SIL quality standards, safeguards and choice mechanisms with Aboriginal and Torres Strait Islander peoples and ACCHOs, embedding self-determination, cultural safety and holistic understandings of health and social and emotional wellbeing throughout commissioning.

Question 2: Quality

What do high-quality SIL supports look like?

High-quality SIL translates these principles into individualised support. It should respond to each participant’s goals, preferences and changing circumstances. In shared arrangements, support should be organised around participants rather than provider convenience, with access to privacy and individual support when needed.

Before entering an arrangement, participants and their chosen supporters need accessible information about staffing, shared support, the process for assessing housemate compatibility and how individual needs will be met. Providers should also demonstrate workforce capability through ongoing training, supervision and reflective practice.

Quality should be assessed through participant outcomes, including autonomy, wellbeing, relationships and community participation, alongside safety and compliance.

Recommendation for Question 2

Require providers to demonstrate how they individualise support, respond to changing needs and protect privacy in shared arrangements, and measure outcomes that matter to participants.

Question 3: Safeguards

How should SIL supports protect the safety, health, wellbeing and rights of participants?

Safeguards must protect participants from physical and psychological harm while upholding their autonomy, dignity, privacy and decision-making. Providers should demonstrate this in everyday practice, including through responses to distress that respect the participant’s preferences and rights.

Risk planning should be developed with each participant and reflect their known triggers, early warning signs and preferred responses.

The reduction and elimination of restrictive practices is central to safe, rights-based SIL.6 Regulated restrictive practices, including chemical, environmental, physical and mechanical restraint and seclusion, restrict a person’s rights and freedom of movement and should only ever be a last resort, authorised, time-limited and delivered under a current behaviour support plan with a clear pathway to reduction and elimination. This warrants particular attention for people with psychosocial disability. Shared and congregate SIL settings can create environmental restraint through locked areas, restricted access to food or belongings and rigid household routines, and psychotropic medication can shade into chemical restraint where it is used to manage behaviour rather than to treat a diagnosed condition. Restrictive practices must never substitute for adequate staffing, suitable housing and physical environment provisions or skilled support. Commissioning should treat restrictive practice use as a potential signal of unmet need or an under-resourced service. Commissioning should require transparent reporting, providers to invest in trauma-informed and recovery-oriented alternatives, positive behaviour support and workforce capability, and in turn, recognise a sustained reduction in restrictive practice use as a marker of quality service provision.

Participants need confidential and independent ways to raise concerns and access advocacy. Complaints processes must be accessible, timely, transparent and free from retaliation. Monitoring should examine how participants are assisted to communicate their views and needs, whether participants feel safe, heard and in control, as well as patterns in complaints, restrictive practices, staff turnover, social isolation and breakdowns in living arrangements.

Recommendations for Question 3

Ensure access to independent advocacy, establish clear requirements for timely and transparent complaints handling, and monitor participant experience without increasing surveillance or control.
Commit to the reduction and elimination of restrictive practices in SIL, supported by transparent reporting and investment in trauma-informed alternatives, positive behaviour support and workforce capability.
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Question 4: Innovation

How can innovation by SIL providers enhance the quality of SIL supports and outcomes for SIL participants?

For people with psychosocial disability, innovation should enable flexible and recovery-oriented support rather than reinforce fixed, one-size-fits-all models. It should strengthen autonomy, relationships and community participation, not be defined primarily by technology, administrative efficiency or reduced staffing costs.

Promising approaches include flexible combinations of individual and shared support, small and consistent support teams, early assistance when a living arrangement becomes unstable, and support that adapts before a participant reaches crisis.

Technology may improve communication, accessibility, rostering or participant control, but it should complement rather than replace relationship-based support. Monitoring and assistive technologies must be chosen with the participant’s informed consent, with clear information about how their data will be collected and used.

Innovation is particularly important at the interface between SIL, hospitals and community-based mental health services. Effective transitions should involve participants and their chosen supporters from the beginning, engage SIL and community-based providers before discharge, and allow gradual familiarisation with a new home and support team. Clear responsibility and funding for transition coordination are essential.

People should not remain in hospital because suitable housing and support cannot be organised. Equally, discharge should not proceed into an unsuitable shared arrangement simply because it is the first vacancy available.

Commissioning can encourage innovation by funding evaluation and giving providers room to design, test and evaluate participant-led models rather than prescribing a single approach. Effective models should be shared across the sector to build collective capability.

Recommendation for Question 4

Fund participant-led, flexible and community-connected models of SIL, including improved hospital transitions and partnerships with community-based mental health organisations, and via funded evaluation, enable innovation against outcomes chosen by participants.

Question 5: Participant choice

How can effective participant choice and control be enhanced, including in regions with smaller populations?

For people with psychosocial disability, effective choice requires practical ways to act when an arrangement is not working, not simply the nominal ability to select a provider. Participants need independent, accessible information and supported decision-making, clear processes for addressing housemate incompatibility, and the ability to change workers or providers without financial or administrative barriers.

In regional, rural and remote Queensland, limited providers, workers and housing options restrict choice. Commissioning should invest in local and specialist provider capacity, culturally safe options, flexible service models and funding that reflects regional delivery costs.

For Aboriginal and Torres Strait Islander participants, locally available choice must include culturally safe options shaped with Aboriginal and Torres Strait Islander communities and community-controlled organisations.

Commissioning must not restrict participants to a narrow panel of providers or favour large organisations because of their procurement capacity.

Recommendations for Question 5

Design commissioning to protect participants’ housing when they change providers and ensure access to independent information and supported decision-making.
Invest in provider diversity and market development in thin markets to sustain culturally safe, locally based services and make participant choice genuine.

Question 6: Provider sustainability

What is needed to ensure that SIL providers are sustainable?

Provider sustainability depends on funding that reflects the full cost of delivering safe, reliable and high-quality support.7 This begins with NDIS pricing that keeps pace with legislated wage obligations.

The Fair Work Commission’s gender-based undervaluation decision, [2026] FWCFB 137, includes an interim wage increase of 15 percent from 1 October 2026 for disability care employees classified under Schedule E, followed by broader changes to the SCHADS Award classification structure from October 2027.3 NDIS pricing must reflect applicable wage increases and the broader cost of maintaining a skilled workforce, rather than requiring providers operating on narrow margins to absorb these costs.

Sustainable funding must also recognise the costs of:

recruiting, retaining, training and supervising a skilled workforce
responding flexibly to fluctuations in participants’ needs
maintaining continuity during hospital admissions and transitions
managing vacancies without rushing housemate selection
providing services in regional, rural and remote communities
safeguarding, reporting and outcome measurement.

Commissioning may provide greater funding certainty, but additional procurement and reporting requirements must be proportionate and funded. Unfunded administrative requirements will fall hardest on smaller, specialist and community-controlled providers, potentially reducing provider diversity and participant choice.

Longer-term, predictable funding would enable providers to maintain stable support teams, invest in workforce development and improve service quality. Commissioning arrangements should be developed with providers and people with lived and living experience so that funding reflects the realities of service delivery.

Recommendation for Question 6

Ensure NDIS pricing and commissioning arrangements fund the full cost of high-quality SIL, including wage obligations, workforce development, vacancies, cultural safety, fluctuating needs and regional delivery, while enabling smaller and specialist providers to participate.

Conclusion

The development of a commissioning approach presents an opportunity to improve SIL, but its success will depend on how it is experienced by participants in their everyday lives. For people with psychosocial disability, good SIL is not simply a safe and stable service. It is support that responds as needs change, respects the person’s home, culture and relationships, and enables recovery, autonomy and participation in community life.

Commissioning should build confidence without creating greater control over participants or narrowing the supports available to them. Its value should ultimately be judged by whether people feel safe, heard and at home, and whether providers can deliver consistent, safe, responsive and sustainable support.

References

1 Gayaa Dhuwi (Proud Spirit) Australia. (2025). Gayaa Dhuwi (Proud Spirit) Declaration framework and implementation plan 2025–2035. 2 National Disability Insurance Agency. (2021). Psychosocial disability recovery-oriented framework. Australian Government. https://www.ndis.gov.au/media/3957/download 3 Fair Work Commission. (2026). Gender-based undervaluation – priority awards review [2026] FWCFB 137 (Matter No. AM2024/19). https://www.fwc.gov.au/documents/decisionssigned/pdf/2026fwcfb137.pdf 4 Milroy H, Kashyap S, Collova JR, Platell M, Gee G, Ohan JL. Identifying the key characteristics of a culturally safe mental health service for Aboriginal and Torres Strait Islander peoples: A qualitative systematic review protocol. Edwards P, editor. PLOS ONE. 2023 Jan 12;18(1): e0280213. 5 United Nations. (2006). Convention on the Rights of Persons with Disabilities. https://www.ohchr.org/en/instruments-mechanisms/instruments/convention-rights-persons-disabilities 6 Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. (2023). Final report: Volume 6, Enabling autonomy and access. Commonwealth of Australia. 7 Independent Health and Aged Care Pricing Authority. (2025). A fresh approach to NDIS pricing: Exploring opportunities for pricing reform – What we’ve heard. Australian Government. https://www.ihacpa.gov.au/sites/default/files/2025-09/A_fresh_approach_to_NDIS_pricing_A_snapshot_of_what_weve_heard.pdf