Occupational
Therapy
Australia

Commissioning of Supported Independent Living (SIL) supports – OTA Submission – September 2026

Introduction

About Occupational Therapy Australia

OTA is the peak professional body representing occupational therapists nationally.

We empower and elevate over 36,000 occupational therapists who in turn work in partnership with individuals and communities to enable meaningful participation in the activities of life.

We’re the single, unifying connection point for occupational therapists across the nation, leading the profession through education, support, and advocacy, so every occupational therapist is informed, inspired and fulfilled in their profession.

As one of Australia’s largest allied health workforces, occupational therapists provide essential supports across primary care, aged care, disability, mental health, veteran care and more.

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About Occupational Therapy

Occupational therapy is a person-centred allied health profession concerned with promoting health, wellbeing and participation through engagement in meaningful and necessary occupations.

Occupational therapists understand that a person’s ability to participate is shaped by the interaction between their individual capabilities, the tasks they want to do, their physical and social environment, and the supports available to them.

A core strength of occupational therapy is building capable environments: shaping the physical environment, routines, supports, relationships and the skills of those around a person so they can exercise greater choice, autonomy and participation in everyday life.

This is especially relevant in supported independent living, where sustainable outcomes depend not on what a participant can do independently, but on whether their home, support arrangements and support workers enable them to participate meaningfully, consistently and safely.

Occupational therapists work across the lifespan with people who need support to participate in everyday life, including people with disability, chronic or progressive conditions, acquired disability and mental health-related support needs.

They have particular expertise in understanding how a person’s abilities, preferences, goals and circumstances interact with everyday demands, and in identifying the environments, relationships, routines and strategies that build capability and enable choice.

Within supported independent living, occupational therapists contribute across the full cycle: assessment, planning, implementation, review and ongoing capacity building. This can include functional capacity assessment, assistive technology and environmental modifications, establishing routines that support participation, and building the capability of families and support workers.

Rather than focusing only on what a person can or cannot do, occupational therapy examines what needs to change in the environment, supports and activities so a person can participate in ways that are meaningful to them.

By building capable environments and support networks, occupational therapists help ensure that individual gains translate into everyday practice and are sustained over time.

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Recommendations

The recommendations below focus on ensuring that SIL is designed to create the conditions in which participants can achieve and sustain their chosen goals and outcomes. This includes ensuring environments, supports, relationships and approaches around a participant enable meaningful participation in everyday life.

Recognising and funding the role of occupational therapy is essential to this approach, given occupational therapists’ expertise in assessing and shaping the interaction between the person, their environment, activities and supports to achieve and sustain these outcomes.

What do high-quality SIL supports look like?

OTA recommends defining quality SIL to include the conditions, supports and environments that enable participants to exercise choice and control, maintain and develop their capabilities, and participate in everyday life in accordance with their goals, alongside the existing definition of safety, reliability and person-centred service.
OTA recommends that high-quality SIL be measured by whether support is delivered at the right intensity, time and duration to build meaningful participation, choice and control, housing stability and recovery goals for participants with psychosocial disability, and to reduce restrictive practices, rather than by the number of support hours delivered or their cost.
OTA recommends that commissioning models require high-quality assessment of the fit between a participant, their environment and their supports during initial matching and set-up, and when arrangements are reviewed, drawing on occupational therapy expertise in this area.
OTA recommends the Department work with OTA to develop standardised assessment approaches and templates for home and living matching, to reduce unnecessary variation while keeping assessment proportionate to individual circumstances.
OTA recommends that quality and complexity assessments under a commissioning model explicitly account for invisible and fluctuating disability.
OTA recommends that, where commissioning applies to participants with psychosocial disability, service and funding arrangements should enable support intensity to increase or decrease in response to changing needs without requiring the participant to move home or disrupting established living arrangements.
OTA recommends assessing any change to participant-to-support-worker ratios against functional, participation and safety outcomes for the specific participant cohort affected.

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

OTA recommends that commissioning require a timely clinical response, drawing on occupational therapy, behaviour support or other appropriate allied health expertise, when behaviours that challenge, functional decline or unmet needs are identified.
OTA recommends requiring SIL providers to provide timely access to occupational therapists and specialist behaviour support, effective implementation and monitoring of behaviour support plans and occupational therapy strategies, and timely referral for review, with a focus on reducing and eliminating regulated restrictive practices.
OTA recommends commissioning require clear escalation and coordination arrangements between SIL providers and mental health services.
OTA recommends ensuring complaints pathways are independent of the SIL provider.
OTA recommends commissioning reinforce existing requirements to separate housing and SIL supports, manage conflicts of interest and enable participants to change provider without putting their housing at risk.

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

OTA recommends funding and rewarding provider innovation that builds independence, autonomy, and participation, including training, assistive technology and home modifications.
OTA recommends commissioning flexible, recovery-oriented staffing models for participants with psychosocial disability, including episodic staffing, worker continuity, and peer workers, alongside occupational therapists and other professionals.
OTA recommends recognising SIL’s role in supporting timely hospital discharge and avoiding premature entry to residential aged care, with allied health input funded accordingly.

What’s needed to ensure that SIL providers are sustainable?

OTA recommends developing safety and quality expectations under any SIL commissioning model alongside NDIS pricing settings, rather than in isolation.
OTA recommends that provider workforce capability requirements for participants with complex support needs include timely access to appropriate allied health expertise.
OTA recommends commissioning include regionally tailored workforce and pricing settings, developed to address thin markets, workforce shortages and distance.
OTA recommends setting distinct workforce capability and funding expectations for commissioned SIL supports delivered to Aboriginal and Torres Strait Islander participants and communities.

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Response to Consultation Questions

Occupational Therapy Australia (OTA) welcomes the opportunity to respond to the Department of Health, Disability and Ageing’s (the Department’s) consultation on the commissioning of Supported Independent Living (SIL) supports. OTA offers our feedback constructively and wants SIL commissioning to succeed.

SIL is one of the largest and most complex support types funded through the NDIS, supporting around 37,000 participants at a cost exceeding $16 billion each year. OTA broadly supports the Department’s exploration of a more active government role in parts of the SIL market. We see this as an opportunity to develop a SIL commissioning model that delivers high quality, safe, and sustainable outcomes for participants.

A commissioning model could establish clearer expectations for quality, safety, provider capability and participant outcomes. However, any commissioning model should be targeted and proportionate, preserve participant choice and control, and recognise the contribution of occupational therapists and other allied health professionals in achieving these outcomes.

Commissioning should not simply purchase hours of support. Done well, it should create the conditions around a participant that maximise autonomy, participation, safety and choice: a capable environment. This principle connects active support, workforce capability, environmental modification, assistive technology, supported decision-making and outcome measurement across this submission.

Existing quality issues within SIL reflect a combination of funding pressures, provider governance, market design and safeguard adequacy. Contributing factors include pricing and staffing models that prioritise roster efficiency over building participants’ independence, capacity and participation, as well as service models which position allied health input as a separate or supplementary service, rather than integrating allied health expertise into core support planning and delivery.

Additionally, SIL commissioning cannot be developed in isolation from NDIS pricing and broader reform. Higher expectations for workforce capability, allied health access and outcome reporting must be supported by funding arrangements that enable providers to meet them. Otherwise, providers may be driven towards minimum compliance rather than the approach that best serves participants.

Occupational therapists bring direct, practical experience of exactly where SIL succeeds or fails for participants day to day. They play a key role in understanding the interaction between the person, their activities, environment and supports, and in using this understanding to inform home and living matching, environmental modifications, assistive technology, support approaches and training, risk enablement, reduction of restrictive practices, and capacity building where aligned with the individual’s goals. OTA sees real value in occupational therapy expertise shaping the commissioning model early, alongside pricing reform, rather than being considered after the model has been established.

We recognise the difficulty of designing a model that lifts quality and safety across a market as large and varied as SIL, without undermining participant choice and control. Our recommendations are not intended to obstruct that goal - each targets a specific, identifiable gap that, left unresolved, introduces risk for the Department as much as for participants and providers.

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Incorporating our recommendations will help the Department to address some of the persistent challenges facing SIL, and avoid recurring costs to the Scheme and to participants, including crisis-driven intervention, restrictive practice use, and provider turnover. They can also improve the fit between participants and their support environments, and strengthening the capability and consistency of those providing support.

Embedding these recommendations in commissioning and service design can help create a SIL model that is safer, more responsive and more sustainable for participants, providers and the Scheme. It will also help the Department gain the social licence and trust needed for these reforms to succeed.

We welcome the opportunity to work directly with the Department, including through the targeted consultation activities planned for the remainder of 2026, to help develop a commissioning model that works for participants and providers alike.

In this submission, OTA responds primarily to Questions 2, 3, 4 and 6 of the consultation paper, where our members’ expertise is most directly relevant, and offers brief comments relevant to Question 5.

Q2. What do high-quality SIL supports look like?

OTA’s response covers four interrelated areas: meaningful participation and quality outcomes; home and living matching, including relational and psychological safety; recognition of invisible, episodic and fluctuating disability; and staffing arrangements.

Capacity building, meaningful participation and quality outcomes

The consultation paper’s definition of SIL quality currently centres on safety, reliability and person-centred service. OTA proposes that additionally, SIL quality should include the conditions, supports and environments that enable participants to exercise choice and control, maintain and develop their capabilities, and participate in everyday life in accordance with their goals (Recommendation 1).

We caution against treating independence and skill development as meaningful outcomes in themselves. From an occupational therapy perspective, independence and skill development are potential means to an outcome. The meaningful outcome is whether the person can participate in everyday life and pursue their goals in ways that are meaningful to them.

Focusing on “independence” can be viewed as ableist as it may imply that needing assistance is a poorer outcome. For many individuals, independence is not the goal or is not possible. A preferred view is to see appropriately designed supports as enabling a person to have autonomy and control.

In the same way, “skill building” places the focus primarily on changing the individual, whereas occupational therapy considers everything around the person, including the environment, assistive technology, routines, support workers and other relationships.

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Meaningful outcomes under SIL commissioning should therefore focus on building capacity in the person and their environment to enable participation, rather than expecting the person to change or “improve” to become more independent or acquire skills.

Quality SIL should be measured by how well available support is used, not simply by how much of it is delivered. Substantial support hours can still produce poor outcomes when support is passive, task-based or organised around a roster rather than a participant’s life. Conversely, well-directed support can build participation and autonomy without requiring more hours.

High-quality SIL is not defined by more support or less support. It is defined by the right support, at the right intensity, at the right time, for the right duration, directed towards the outcomes that matter to the participant (Recommendation 2). This is what OTA means by active support: support that is deployed purposefully and responsively to build participation, autonomy, capability and quality of life, rather than delivered as a fixed, passive routine.

On this view, efficiency means getting greater participant value from the resources already invested in SIL, not simply reducing hours.

Occupational therapists are key enablers of these outcomes. Support workers in SIL can embed and reinforce capacity building and participation strategies developed through occupational therapy within participants’ everyday routines, activities and environments. For the NDIS, this creates an opportunity to maximise the impact of existing capacity-building investment, rather than treating professional intervention and day-to-day support as separate activities.

Home and living matching, including psychological safety

Home and living arrangement matching requires a specialised assessment process because decisions about who shares a home, how the environment is set up and how supports are rostered around a participant’s routine have a direct impact on safety, wellbeing and outcomes.

Matching should consider relational and psychological safety, not simply physical accessibility, support intensity, vacancies or staffing efficiencies. This includes compatibility with household routines, noise and sleep patterns, sensory and communication needs, cultural needs, visitors, lifestyle preferences, opportunities for meaningful relationships and community participation, and the participant’s goals for their home life.

Participants should also have meaningful input into decisions relating to who they live with and who supports them, and access to a safe process to review an arrangement that is not working. Occupational therapy expertise can support informed decision-making by assessing the fit between the person, their environment, occupations/activities and support arrangements, while ensuring the participant remains the decision-maker.

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This can be given practical effect through a supported decision-making framework. Occupational therapists can work with the participant, their family and support team to identify how the person communicates preference, what decisions they make independently, what support helps them understand options, how information should be presented, who they want involved, how risk is approached, and how supporters build the person’s agency rather than inadvertently deciding for them. This framework then becomes part of the capable environment around the person, giving practical effect to choice and control rather than stating it as an aspiration.

Commissioning models should require this standard of assessment during initial matching and set-up, and when arrangements are reviewed (Recommendation 3). Occupational therapists, with their focus on the fit between a person, their environment and their supports, are particularly well placed to provide it.

OTA is well placed to work with the Department to develop standardised assessment approaches and templates for home and living matching, reducing unnecessary variation while keeping assessment proportionate to each participant’s circumstances (Recommendation 4).

Occupational therapists, with their strong focus on context, help build capable environments, and the physical, relational and support settings that make a person’s chosen outcomes achievable and sustainable. This makes occupational therapists uniquely well suited to this specialised assessment task.

Recognition of invisible, episodic and fluctuating disability

Quality assessment in SIL should not default to visible or physical support needs when identifying complexity. Participants with invisible disability, including psychosocial disability, cognitive impairment, chronic fatigue or sensory processing needs, can have support requirements that are not immediately apparent but significantly affect their capacity to live independently.

A commissioning model that defines quality or complexity primarily through physical support intensity risks under-recognising these participants in both home and living matching and ongoing support planning. Quality and complexity assessments should explicitly account for invisible and fluctuating disability, not only observable functional needs (Recommendation 5).

When done well, SIL commissioning can become a lever for a more consistent, proportionate and sustainable system - this means matching the intensity and type of support to a person’s need and complexity rather than applying a single model to everyone.

As an example, psychosocial disability can also be episodic. A participant may need more support during a period of distress or deterioration and less at other times. Where commissioning applies to participants with psychosocial disability, service and funding arrangements should enable support intensity to increase or decrease in response to changing needs without requiring the participant to move home or disrupting established living arrangements (Recommendation 6).

Staffing arrangements and shared-support ratios

Each individual participant will have unique support needs, and those supports may be shared across participants. This can lead to efficiency gains and improved cost effectiveness for the Scheme.

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However, increased participant-to-support worker ratios that are not underpinned by thorough assessment can introduce risks of compromised outcomes. Where ratios increase without proper assessment, workers may have less time for anything beyond personal care and safety. This can undermine outcomes, as skill development, tailored routines and supporting meaningful participation require time and individualised attention that a stretched roster may not provide.

CASE STUDY

Shared support in a SIL house: The impact of occupational therapy

Three participants share a SIL house and receive shared support for household tasks such as meal preparation and shopping. Sharing these supports creates efficiencies, but each participant has different functional needs, goals and routines:

One participant has an episodic condition affecting energy, cognition and ability to initiate tasks. Some days they can prepare a meal independently; other days they need prompting and assistance.

Another participant has sensory sensitivities and needs a quieter environment and flexible routines.

The third participant is a wheelchair user with impaired mobility and motor skills. They may need individualised assistance or environmental adaptations for tasks such as meal preparation, transfers, accessing the community and reaching kitchen items.

An occupational therapist can assess each participant’s functional capacity, routines, environment and goals. This identifies which supports can be shared and where differences in intensity, timing or type of support call for an individualised approach.

Occupational therapy input keeps the activity shared while tailoring how support is delivered. For example, an occupational therapist might recommend graded prompting for the participant with fluctuating capacity, environmental and routine adjustments for the participant with sensory sensitivities, and accessible equipment with individual assistance for the wheelchair user. All three can keep sharing meal-preparation support, delivered in a way that suits each person.

Without individual assessment, two problems can arise:

Over-support: Participants receive the same level of support for operational convenience, even when some could do more independently.

Under-support: Individual needs are overlooked because support is structured around a shared roster, risking safety, participation and outcomes.

Occupational therapy input allows the NDIS to capture the efficiencies of shared support without assuming participants have the same needs, or that the same level of support suits everyone at all times. It ensures cost efficiencies do not come at the expense of safety, participation or individual outcomes.

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The lesson is not that support should increase or decrease. It is that available support should be used intelligently, varying by need while retaining the efficiencies of sharing where appropriate. This is what proportionate commissioning should look like in practice.

Occupational therapists are well positioned to ensure that individual outcomes are met. Any change to participant-to-support-worker ratios should be assessed against functional, participation and safety outcomes for the specific participant affected, rather than treated as a uniform efficiency or cost-saving measure across the SIL market (Recommendation 7).

Q3. How should SIL supports protect the safety, health, wellbeing and rights of participants?

OTA’s response covers four areas: proactive identification of risk and unmet needs; reducing restrictive practices; coordinating with mental health and other services; and independent complaints, advocacy and housing safeguards.

Proactive identification and response

Safeguards in SIL should be proactive, rather than responsive, and while incident reporting after harm has occurred is necessary, it is insufficient. Providers should have participant-led plans for recognising early signs of changing needs, such as deterioration, and connecting the participant with appropriate clinical, psychosocial and allied health support.

People may communicate unmet needs, distress, discomfort, an emerging mental health crisis, or a lack of control through their behaviour. A change in behaviour should not automatically be treated as concerning behaviour to be managed through a more restrictive response.

Occupational therapists have a holistic lens, that considers the interaction between the person, their activities, environment and support network. This enables them to identify when environmental factors, the demands of an activity, or the way support is provided may be contributing to behaviour that presents a risk to the person or others. Shaping a more adaptive environment around the person is often the more effective and less restrictive response. Occupational therapists are specifically trained to assess these factors and advise on appropriate changes to the environment, activities and supports.

Where behaviours that challenge present a risk to the person or others, occupational therapists and behaviour support practitioners often work together, combining functional assessment and environmental and activity modification with behaviour support planning to develop a response suited to the person, their goals and their circumstances.

OTA recommends that commissioning require a timely clinical response, drawing on occupational therapy, behaviour support or other appropriate allied health expertise, when behaviours that challenge, functional decline or unmet needs are identified (Recommendation 8).

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Reducing and eliminating restrictive practices

Restrictive practices are a known risk in SIL, particularly in shared-support settings where staffing models are designed around groups rather than individuals. However, they should not be an inherent feature of the SIL model.

High-quality SIL should actively minimise and reduce the use of restrictive practices, rather than allowing them to become an unintended consequence of staffing models, shared living arrangements or operational convenience. This requires understanding and addressing the underlying factors contributing to behaviours that place the individual or others at risk, including the person’s environment, routines, sensory needs, communication and opportunities for meaningful participation.

Occupational therapists are uniquely qualified to contribute by assessing the interaction between the person, their environment, their everyday occupations and their supports. Occupational therapists partner with participants and their supports to identify practical changes that increase participation, autonomy and safety while reducing the need for restrictive responses.

Commissioning should require SIL providers to demonstrate timely access to occupational therapists and specialist behaviour support, effective implementation and monitoring of behaviour support plans and occupational therapy strategies, and timely referral for review where needed. This should include a clear focus on reducing and eliminating regulated restrictive practices, with relevant occupational therapy, allied health and clinical input incorporated where appropriate (Recommendation 9).

Mental health escalation and service coordination

SIL providers are not a substitute for mental health services. Commissioning should require clear escalation and coordination arrangements, including consent-based information sharing, while protecting the participant’s privacy and supporting a health-led, least restrictive response wherever appropriate (Recommendation 10). Responses should be proportionate, and police and emergency services should not be the default where there is no immediate risk of harm.

Independent complaints, advocacy and housing safeguards

Complaints pathways should be independent. Where a provider controls both a participant’s SIL supports and their home environment, participants and families may reasonably feel unable to raise concerns freely. OTA recommends that the commissioning model require access to a complaints pathway independent of the SIL provider (Recommendation 11).

Supported decision-making and independent advocacy are important safeguards, particularly where a SIL provider or a related organisation also provides a participant’s housing. Commissioning should reinforce and monitor existing requirements to separate housing and support arrangements, manage conflicts of interest and enable participants to change their SIL provider without putting their housing at risk. Particularly in thin markets, these protections should be supported by independent advice and viable alternatives (Recommendation 12).

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Q4. How can innovation enhance the quality of SIL supports and outcomes for SIL participants?

Innovation in SIL should be defined broadly, covering workforce and service models as well as technology.

Assistive technology and home modifications are direct, tangible ways of building a capable environment around a participant, reducing reliance on paid support while expanding what a person can do for themselves. These are well-established innovation levers that can reduce ongoing support needs while improving a participant’s independence, autonomy, participation and quality of life.

Innovation is not restricted to technology, it can also be demonstrated in how services are delivered. We also propose rewarding specific training for support workers in strengths-based, participation-focussed and capacity-building approaches, rather than task-oriented support.

Commissioning is not only a mechanism for purchasing services. It can shape provider behaviour. A model could reward evidence that providers are delivering meaningful participation and participant-defined outcomes, effective supported decision-making, active rather than task-based support, capable environments, workforce capability, reduced restrictive practices, stability of home and relationships, and support that responds to changing need. This would better align provider incentives with participant outcomes than funding support hours alone (Recommendation 13).

At the same time, commissioning and pricing must work together. Rewarding innovation through commissioning will achieve little if the underlying funding does not cover the allied health input required to design, implement, embed and review it.

For participants with psychosocial disability, innovation may also include staffing that flexes with episodic need, greater continuity of support workers and models that connect SIL with clinical and community-managed psychosocial services (Recommendation 14). Peer workers can add significant value alongside occupational therapists and other mental health and psychosocial professionals within recovery-oriented models. These approaches should be designed around how participants’ support needs change over time, rather than around a fixed roster.

OTA also encourages the Department to consider SIL’s role at key transition points, including supporting timely hospital discharge and avoiding premature entry to residential aged care (Recommendation 15). Occupational therapists are central to housing, equipment and support planning at these points, and commissioning arrangements should recognise and fund this role.

Q5. How can effective participant choice and control be enhanced, including in regions with smaller populations?

OTA’s views most relevant to choice and control appear in our responses to Questions 2 and 3 - a participant’s genuine say over who they live with, who supports them, and how they are supported, and a safe way to revisit an arrangement that is not working, complaints pathways independent of the SIL provider, and the ability to change provider without putting housing at risk.

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Where commissioning requires allied health input, that input should remain the participant’s to direct. Participants, or their support coordinator on their behalf, should refer to an occupational therapist or other practitioner of their choosing, using funding held in the participant’s own plan, rather than having allied health input arranged or delivered through the SIL provider. Keeping this referral pathway with the participant protects both the quality of that advice and maintains the participant’s choice and control.

Quality occupational therapy input enables informed choice and supported decision-making, enabling a participant to achieve the life and outcomes they choose, rather than assessing or determining that choice on their behalf.

Independent allied health advice and complaints pathways are especially important where participants have few viable alternatives. These protections are particularly important in thin markets, where limited providers, workers and housing options may leave one provider controlling a participant’s housing, daily support and access to allied health services.

Q6. What’s needed to ensure that SIL providers are sustainable?

Pricing that supports quality

Provider sustainability and pricing adequacy cannot be considered separately. Providers cannot deliver higher quality, allied health-informed SIL if pricing settings do not fund allied health involvement in support planning, implementation, and review. OTA has raised concerns about pricing methodology through the Annual Pricing Review process. OTA recommends developing quality expectations under any SIL commissioning model alongside NDIS pricing settings, rather than in isolation (Recommendation 16).

Workforce and allied health capability

Workforce capability requirements under a commissioning model should extend beyond the number and basic competencies of direct support workers to include access to appropriate allied health expertise.

For participants with complex, changing or fluctuating support needs, provider capability should include reliable access to timely occupational therapy and other allied health input. This should not replace a participant’s right to choose an independent practitioner, but should ensure that providers have the capability to recognise when professional input is required, and to work effectively with the participant’s chosen practitioners (Recommendation 17).

Allied health input can be critical to the quality of SIL by helping providers understand individual functional needs, identify opportunities for capacity building and participation, and adapt the person’s environment, routines, assistive technology and support approaches.

Importantly, this expertise can support the translation of professional recommendations into everyday practice, working alongside support workers to embed strategies within the participant’s routines and activities rather than treating allied health intervention as separate from day-to-day support.

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There is an opportunity for OTA to work with the Department to build contemporary occupational therapy capability for emerging models of home and living support, ensuring workforce settings address capability and quality, not simply workforce numbers or transactional or task-based approaches to support.

This could include defining the knowledge, skills and practice capabilities required of occupational therapists working in SIL and supporting providers, participants and the broader workforce to understand the value of occupational therapists being part of the team around the individual, and how occupational therapy can uniquely contribute to participant outcomes.

OTA’s existing capability frameworks provide a strong foundation for this work. Developed in collaboration with occupational therapy subject matter experts, these frameworks articulate contemporary, evidence-informed, best practice across relevant areas.

These frameworks are complemented by OTA’s Practice Essentials learning modules, which provide targeted foundational learning that supports practitioners to translate knowledge and capability into good practice across different settings and sectors. This provides a potential model for government and the sector to move from identifying workforce capability requirements to actively building the capability needed to deliver quality supports.

There is also an opportunity to adapt this capability-to-learning approach for the broader SIL support workforce. Capability frameworks could define the core knowledge, skills and behaviours expected of support workers, with targeted learning modules providing practical guidance on applying these capabilities in everyday support.

This could include areas such as enabling rather than doing for, supporting choice and control, recognising changes in functional capacity, embedding capacity-building strategies, supporting meaningful participation, responding to sensory and communication needs, and using assistive technology and environmental strategies appropriately.

Read together, these capabilities describe what a contemporary SIL workforce looks like: one able to deliver active support by enabling rather than doing for, recognising fluctuating capacity, adapting the intensity and timing of support, and knowing when specialist input is required.

A tiered approach could enable core capabilities for all SIL workers, with more targeted learning for workers supporting participants with complex or changing needs. This would provide a scalable mechanism for strengthening workforce capability while ensuring that learning is connected to the realities of everyday practice.

This would support a shift from thinking about workforce capability as “How many workers do we have?” to also asking “Does our workforce have the right capability to enable high-quality, individualised outcomes?”

Together, capability frameworks and targeted learning provide a pathway for the SIL workforce, from defining what good looks like, to building the workforce capability to deliver it, to embedding that capability in everyday support. OTA is well positioned to work with government on this approach, drawing on its established capability frameworks, subject matter expertise and education resources.

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Regional and remote service viability

Provider sustainability also requires tailored approaches in regional and remote areas, where thin markets, workforce shortages and distance can compound one another. These factors interact rather than operate independently, so a solution designed for one, such as higher base pricing, may still fail if workforce shortages or distance aren’t addressed alongside it.

A commissioning model should not assume that a single national workforce and pricing approach will be effective in every location. OTA recommends commissioning include regionally tailored workforce and pricing settings, developed to address thin markets, workforce shortages and distance as compounding factors, rather than separately (Recommendation 18).

Culturally safe commissioning

Commissioning must also support culturally safe SIL services for Aboriginal and Torres Strait Islander participants. This requires Indigenous-led design and true partnership with Aboriginal and Torres Strait Islander community-controlled organisations, practitioners and communities. Commissioning should establish appropriate workforce capability and funding expectations rather than treating cultural safety in addition to the generic capability standard (Recommendation 19).

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Conclusion

OTA thanks the Department of Health, Disability and Ageing for the opportunity to provide feedback on SIL commissioning and looks forward to further engagement on this issue.

SIL will only achieve the quality, safety and independence outcomes this reform seeks if occupational therapists and other allied health professionals are recognised, funded and embedded as core to how supports are planned, delivered and monitored, not treated as optional, incidental or separate. This requires commissioning to be developed alongside pricing reform, so new expectations are backed by the funding needed to meet them.

As set out throughout this submission, occupational therapy can contribute across the SIL system to create the conditions in which participant outcomes are achievable and sustainable. From home and living matching to capacity building, assistive technology, environmental modification and restrictive practice reduction, occupational therapists bring expertise in understanding the interaction between the person, their environment, their daily occupations and the supports around them.

This expertise can help the NDIS move beyond a model primarily focused on delivering support hours towards one that optimises the right mix of supports, builds and maintains participant capability, enables meaningful participation and delivers outcomes that matter to each person. It can also help identify opportunities to use shared supports effectively without compromising individual needs, and to ensure that professional recommendations are translated into everyday practice through the support workforce.

Incorporating these recommendations will help reduce the risk of avoidable costs to the Scheme and to participants, arising from inappropriate living arrangements, placement breakdown, crisis-driven intervention, restrictive practices, and supports that do not achieve their intended outcomes. Most importantly, it will support a SIL commissioning model in which efficiency is achieved through better assessment, support design and outcomes, rather than through standardisation or reduced support at the expense of participant wellbeing.

OTA is ready to work with government to translate these principles into practical commissioning architecture, including consistent and proportionate assessment approaches, supported decision-making frameworks, workforce capability requirements, meaningful outcome measures, and scalable approaches to building capable environments and delivering active support.

The question for SIL reform is not how to buy fewer hours, or even how to buy more occupational therapy. It is how to use the substantial resources already invested in SIL to create capable environments in which people exercise choice and control and participate in lives they choose.

OTA requests to be included in the targeted consultation activities planned for the remainder of 2026, given our members’ direct role in SIL assessment, home and living matching, and skill-building support.

We can be reached at policy@otaus.com.au

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Section Heading here

This Guideline sets out the actions needed to develop and approve an OTA Position Statement. It also provides a framework for the Position Statement document to ensure comprehensiveness and clarity.

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