SUBMISSION TO THE DEPARTMENT OF HEALTH, AGEING AND DISABILITY

NDIS Support Coordination and Connection (SCC) Reform

Responding to complex and intersecting needs through an equity-oriented SCC model

OCTOBER 2

Authors: Dr Grazia Catalano (lead author) and the National Ethnic Disability Alliance

Hardwick House Unit 1, 6 Phipps Close
Deakin, ACT 2600

neda.org.au

policy@neda.org.au

About the authors:

Dr Grazia Catalano has played key roles in the development of legislation and policy impacting disability services and managed the delivery of regional disability services in Queensland. Grazia has worked in both government and non-government sectors, and as a researcher in the areas of human rights, criminology and inclusive education.

Grazia has held senior roles in government including implementation of a significant state-wide program of reform impacting government and non-government disability service providers that support individuals with an intellectual disability who exhibit behaviours of concern. Grazia has led collaborations involving several agencies/organisations to achieve co-ordinated and integrated service delivery models, multi-agency funding partnerships, and joint initiatives with tertiary education sectors. Most recently Grazia has been a lead quality auditor of the National Disability Insurance Scheme, planning and undertaking quality audits and technical reviews of quality audit reports. She continues to be involved in the disability sector through systemic advocacy and maintains an active interest in the discourse of quality.

The National Ethnic Disability Alliance (NEDA) is Australia’s national peak body representing people with disability from culturally and linguistically diverse (CALD) backgrounds, their families, and carers. NEDA holds Disability Representative Organisation (DRO) status and United Nations Economic and Social Council (ECOSOC) consultative status. We are governed by a Board with a majority of people with disability from migrant or refugee backgrounds and have member organisations in every state and territory. NEDA advocates federally for the human rights, inclusion and equitable access of CALD people with disability across all aspects of Australian life.

Introduction

Background

Support Coordination has always been recognised as an important component of the NDIS by the sector, and over time specific areas or niches of expertise have been recognised. These included expert responses delineated by complexity of circumstances, different cultures/ethnicity, or type of disability.

The NDIA sought to build the capability of support coordinators through initiatives such as the Exceptionally Complex Support Needs Program (ECSNP) which was a 2-year program commencing in late 2019. Consultation feedback as part of this program highlighted a range of training programs, communities of practice and other initiatives being led and delivered by the sector. This initiative recognised the role of support coordinators in safeguarding participants and promoting quality of services and supports, particularly for participants experiencing complex circumstances.

In 2020 the NDIA issued a Support Coordination Discussion Paper for consultation, and in 2021, the NDIS/NDIA published a paper on Improving Support Coordination for Participants. The paper indicated that greater clarity was needed on the role of support coordinators to help drive more consistent, quality outcomes from support coordination services; not slipping into the role of independent advocate; and avoiding conflict of interest by preventing providers from delivering both support coordination and other funded supports in the participant’s plan.

The NDIS Commission’s Own Motion Inquiry into support coordination and plan management (Part 1) in 2023 identified serious quality, safeguarding and integrity risks. Part 1’s findings called for intermediary supports to have stronger standards and independence to increase quality, reduce conflict of interest and ensure participants are able to exercise genuine choice and control. Part 2 Terms of Reference required the NDIS Commission to examine if changes should be made to address quality and safeguarding concerns and support the positive contributions made by good support coordination identified in Part 1 of the inquiry.

This consultation

The Consultation Paper released in September 2026 by the Department is seeking input to the commissioning model for Support Coordination and Connect (SCC and SCC+). It states that the proposed model outlined in the consultation paper is informed by extensive consultation and engagement over the past three years regarding ‘intermediary’ or ‘navigation’ services. This includes the recommendations of the NDIS Review, the findings of the Disability Royal Commission, and the recommendations from the NDIS Quality and Safeguards Commission Inquiry into Support Coordination.

It would also have been important make explicit reference to the human rights principles drawn from the UNCRPD, upon which the NDIS legislation, rules and policies are based, and to make explicit that any new commissioning model as part of this reform would be equity-oriented. It is pleasing to see recognised in the Consultation Paper the voices and lived experiences of First Nations people, people with psychosocial disability, people from culturally and linguistically diverse backgrounds, and people in regional, rural and remote areas. This constitutes a first step in the development of an equity-oriented commissioning model.

The Consultation Paper highlights that these voices, as part of broader consultations in 2024-2025, had raised, amongst other issues:

the need for stronger support for people with complex and intersecting needs, and
improved access in thin markets particularly in regional, rural and remote areas and for specific cohorts.

The Consultation Paper states that the functions of the proposed new SCC services will be:

collaboration to understand the participant’s service goals and needs
connection to link participants to available supports
coordination of supports.

And it is proposed that the model will have two service levels. SCC: for participants who require ongoing support to connect with and coordinate supports and services. SCC+: for participants with very complex circumstances, including intensive support coordination needs, significant safety considerations, complex support environments, multiple interacting service systems, and heightened risk of disengagement. SCC+ services will be limited to a small proportion of NDIS participants, and will likely involve more contact hours and specialist workforce skills.

The Consultation Paper explicitly states that

“We have heard previously that support coordination and connection services must be accessible, inclusive and responsive to the diverse needs of participants. This includes recognising that people with disability may experience additional barriers due to intersectional factors such as culture, language, geographic location, gender, sexuality, socio-economic circumstances or interactions with other service systems. The proposed service would provide additional support within the SCC and SCC+ service levels for people with diverse and intersectional needs.”

The model is further qualified in the consultation paper by stating that SCC services will not provide advocacy services, and, they will not routinely provide other NDIS-funded supports. The issue of conflict of interest remains unresolved with this wording and it is addressed as part of this submission.

Focus of this submission

This submission presents the case for an equity-based commissioning model, with a focus on specialisation cohorts including cohorts defined by cultural, ethnic and language differences.

In the context of this submission, specialisation cohorts are people with disability

from culturally, ethnically, and linguistically diverse backgrounds who demonstrate culturally specific support needs
who are Aboriginal or Torres Strait Islander and have culturally specific support needs, or
live in regional, rural and remote areas.

The focus of this submission is primarily on people with disability from culturally, ethnically, and linguistically diverse backgrounds who demonstrate culturally specific support needs.

This submission presents three models that offer culturally appropriate SCC service options for participants. These models seek to protect CALD participants’ right to culturally appropriate choice. The commissioning model and reform process needs to preserve participant choice. CALD

communities need to be appropriately represented within commissioned SCC services, and a choice between CALD-specific organisations provided wherever possible. Commissioned mainstream organisations (organisations that are not ethno-specific or multicultural) should be required to demonstrate cultural capabilities at the organisational and at the practitioner levels.

Several of the consultation questions are grouped by Topics which are addressed in this submission.

TOPIC	Consultation questions
Responding to complex and intersecting needs	Which participant groups will benefit most from the SCC service? What do their needs for connection and coordination of supports look like?
Capabilities of SCC and SCC+ practitioners	What experience, skills and knowledge do you look for in an SCC worker?
Operating models for SCC and SCC+ services	How can the SCC service best support participants who face additional barriers, including those experiencing complex and overlapping support needs or requiring decision-making support?
	How can the future SCC model attract, build and retain workforce capability, including retaining participant relationships?
	How can the SCC service best support participants in regional, rural and remote areas, or other thin markets, where support options may be limited?

Recommendations

That the proposed commissioning documentation require that options for SCC services address the needs of the specialisation cohorts: people with disability
- from culturally, ethnically, and linguistically diverse backgrounds who demonstrate culturally specific support needs
- who are Aboriginal or Torres Strait Islander and have culturally specific support needs, or
- live in regional, rural and remote areas.
That the proposed SCC Commissioning approach reflect human rights principles and participant rights as highlighted in the NDIS Practice Standards- the right to
- Person-centred supports
- Individual values and beliefs
- Privacy and Dignity
- Independence and Informed Choice

Freedom from Violence, Abuse, Neglect, Exploitation and Discrimination

And that the proposed commissioning documentation require a provider to demonstrate an understanding of how these rights are/will be upheld and evidenced in the provision of SCC and SCC+ services to chosen specialisation cohorts.

That the proposed commissioning documentation require that SCC and SCC+ services offer CALD participants culturally appropriate choice of SCC services in target locations informed by population data.
That consideration be given access to SCC services to all participants from CALD backgrounds, and to ensure that CALD participants who experience complex and intersecting needs be provided with access to SCC+ services.
That if mainstream organisations (organisations which are not ethno-specific or multicultural) wish to draw on and access specialist expertise to ensure delivery of culturally-specific and culturally-responsive services to specialisation cohorts, they will need to include such organisations in SCC service partnerships and allocate a budget to these organisations to provide their expert training, advice, and more to SCC services.
That the proposed commissioning documentation require a provider to indicate if they intend targeting specialisation cohorts and where they indicate the CALD cohort, be required to demonstrate how they will support CALD participants: a. as a culturally responsive organisation, and b. maintain a skilled workforce of culturally competent SCC practitioners.
That the proposed commissioning process provide a guide to core capabilities and specialised capabilities required for delivery of SCC and of SCC+ services (noting those presented for consideration in this submission).
That consideration be given to the three SCC/SCC+ service models presented in this submission a. Expansion of existing CALD services delivered by an ethno-specific /multicultural organisations to include an SCC service b. Co-location of CALD SCC with non-CALD SCC services in urban areas c. New consortiums in regional and rural areas bringing together SCC/SCC+ services that reach specialisation cohorts.

And noting that all three models must be designed to deliver:

Participants’ culturally appropriate choice
Practitioners’ cultural competence
Organisation’s cultural responsiveness.

That the proposed SCC Commissioning approach give preference to registered NDIS service providers that are not conflicted by their intention to provide SCC services together with other disability services, whether those other disability services and supports be funded by NDIS or other agency; and that the commissioning process ensure safeguards for participants who may influenced to agree to a conflicted arrangement by, for example, involving an independent advocate as part of the supported decision making process.

That the SCC service reform process give consideration to how the budget for the commissioned services will acknowledge the additional time and resources required to deliver SCC and SCC+ services to participants whose cultural, ethnic or linguistic backgrounds may not be adequately reflected in mainstream service systems.

Responding to complex and intersecting needs

Cultural inclusion

This submission presents the case for ensuring that SCC and SCC+ services are designed to respond to the needs of those participants from backgrounds different from the mainstream culture. The vulnerability of some participant cohorts does not come about because of their different cultural, ethnic or language backgrounds, but as a result of systemic barriers built into service systems, and community attitudes which do not accommodate difference.

The NDIS market is not yet responsive to the principles of cultural inclusion, which is the reason that some participant cohorts experience significant difficulty accessing and navigating the NDIS, and grapple with inadequacy of appropriate supports. Often these participant cohorts may not be aware of or able to access multicultural disability advocacy. This an enduring concern raised by representative and advocacy organisations and reflected across successive government inquiries and reviews.

Cultural responsiveness

To provide support coordination to migrants and refugees with disability, SCC service providers and practitioners will need to have an understanding of:

The perceptions of disability within migrant and refugee cultures
How to engage with migrant and refugee family and community structures
The migrant experience of settling in a new country and seeking inclusion in a new community
Resettlement needs of individuals and families, particularly in communities where prevailing community attitudes may present barriers to social inclusion and participation.
The refugee experience of loss of home, grief in displacement, and the lived experience of persons who may have acquired disabilities (trauma, physical and psychological) as part of violent displacement and stays in refugee camps
Varying levels of proficiency in English, and in health literacy in Australia, acknowledging that some people may or may not have informal supports that may or may not also have similar language and systems barriers, thus presenting additional barriers.
The economic status of migrant and refugee communities, including impacts of government policies (Centrelink, Medicare) on migrants and refugees with disability (e.g., 10 years residency required prior to accessing a disability support pension)
The potential impacts of the intersection of sex/gender, race, ethnic origin, religion, sexual orientation, and disability.

Awareness of these social and economic circumstances and the possible biopsychosocial impacts on the individual requires specialist knowledge and practice.

Navigating the NDIS assumes a level of knowledge about disability services, Australian systems and individual advocacy that participants and their informal supports may not have. This is not limited to people who are newly arrived or who have limited English. Even where a participant was born in Australia as a second-generation migrant, their family/ parents or other informal supports may not

have the system knowledge or language and advocacy skills required to help them navigate the NDIS or support their self-advocacy.

There is a strong case for SCC services being available to all CALD participants, and SCC+ services to those in the cohort with more complex and intersecting needs. And, for this specialisation cohort (CALD) the navigation through multiple service systems including disability, health, housing, education, and employment, requires practitioners to have competence in a core set of competencies to deliver SCC and a specialised set of capabilities for SCC+ services. A set of core and specialised capabilities relating to engagement, planning, connection and coordination are discussed below as part of this submission.

Capabilities of SCC and SCC+ practitioners.

Practitioner capabilities are nurtured by an organisational culture which acknowledges the rights of participants, enhanced by evidence-based resources and tools with which to undertake their roles, and enriched through sustained professional development. Providing SCC services in migrant and refugee communities requires core SCC capabilities and specialised capabilities for SCC+ services.

Making connections

For practitioners tasked with connecting participants with services and supports in the community, it is important that the practitioner can relate to that community where the participant lives. There is a strong case for the practitioner to be sufficiently aware of the cultural and social capital in the participant’s communities to the extent that the practitioner’s professional relationships with that community can lead to the harnessing of community resources that could be available to the participant. In this way also, the practitioner is able to find ways to expand participant opportunities and choice at individual and community levels.

For practitioners tasked with coordinating services and supports around the participant a number of core skills and capabilities have been identified through a scoping review of peer-reviewed literature and grey literature (Cubis et al, 2026). These have been taken account of in the table below.

The following tables summarises capabilities for all SCC practitioners, as well as additional capabilities for SCC+ practitioners working with participants from different cultural, ethnic and language backgrounds who experience complex and intersecting needs related to their disability and circumstances.

Core capabilities for all SCC practitioners

Core capabilities - all SCC
Understanding NDIS processes
Understanding disability
Taking account of lived experience and applying trauma informed practice
Communicating openly and respectfully, and listening carefully
Demonstrating professional understanding and empathy
Ensuring confidentiality and consent through supported decision making principles and practices
Managing budgets appropriately and competently
Collaborating to achieve desired outcomes
Negotiating and facilitating adaptive solutions
Educating stakeholders of the participant circumstances and requirements
Applying cultural awareness
Being aware of local services and supports and provider networks

Core capabilities - all SCC
Supporting self-advocacy where possible

Specialised capabilities for SCC+ practitioners

Specialised capabilities - SCC+
Engaging and working with professional interpreter services with the participant’s preferred interpreters
Explaining NDIS processes in culturally relevant ways
Ensuring confidentiality and consent through informed decision-making having regard for family dynamics, language and cultural context
Applying a cultural lens to supported decision making processes
Applying cultural competence and ensuring culturally safe environments for discussing participant plans, goals and options
Being open to working within meeting arrangements preferred by the participant, for example, to include a significant person from their community
Distinguishing between barriers arising from language, cultural context and unfamiliarity with Australian systems and those arising from a participant’s disability, and adapting support accordingly
Having extensive professional competence and knowledge across different types of disability and intersections with health, mental health and other sectors
Promoting the involvement of independent advocates for those with complex needs and identifying multicultural disability advocacy organisations
Identifying experienced allied health providers who are using technology effectively to provide assessments and therapeutic supports to specialised cohorts in rural and remote areas to ensure timely service connections

Professional competence

in view of the complex circumstances targeted by SCC+ services, qualifications should be a requirement and the pricing arrangements should reflect this, as it does under the current arrangements. Under the current arrangements Specialist Support Coordinators are required to have qualifications such as Psychologist, Occupational Therapist, Social Worker, or Mental Health Nurse (NDIS Pricing Arrangements 25-26). Professional qualifications should remain as the requirement for all SCC+ practitioners. Additionally, consideration should be given to an expansion of professional qualifications to include other relevant bachelor level qualifications from across the fields of study in disability and health sciences.

Across sectors and services there remains a poor understanding of the needs of individuals experiencing psychosocial disability and the types of supports needed. Feedback to date appears to have sufficiently demonstrated that the needs of participants experiencing psychosocial disability, generally, have had some poor responses under the NDIS. Participants require coordination of supports by qualified practitioners who have a deep understanding of the challenges of mental ill-health and disabilities emanating.

This has been shown to be an area of particular concern within the specialised cohorts. Recent research (e.g. Hamilton et al, 2024) provides the case for strengthening specialised coordination support to this participant group to navigate complex service systems and to identify and maintain engagement with services that understand their particular needs.

Cultural competence and cultural safety

Research tells us that much of the research around cultural safety conflates or confuses this with cultural competence. At the individual practitioner level, a culturally competent practice is described as awareness and knowledge of cultural groups that differ from their own, skills that allow them to work cross-culturally, being culturally sensitive and exhibiting cultural humility at the inter-personal level. Culturally competent individuals are important contributors to developing culturally safe systems.

However, cultural safety is operationalised at the systemic level where power inequities are challenged to bring about structural changes to mainstream institutions, and service infrastructure. Responsibility for cultural safety lies with the organisation and its systems. This responsibility requires the organisation to address the power imbalance with service users, especially in cases where service users are considered different or from minorities. Equity-oriented and culturally safe organisations are characterised as inclusive, collaborative and engaging with service users through culturally appropriate communication.

In the healthcare area an investigation into the challenges of providing services to migrants with disability (Olaussen and Renzaho, 2016) found that at that time the models proffered across the health sector did not address the needs of migrants with disability. Feedback from carers of migrants with disability expressed concern about lack of family-centred and strengths-based practice amongst practitioners and limited use of language services. These findings pointed to the need for greater emphasis on cultural competence at the organisational level and in further development of their professional practice. It is interesting to note that even 10 years later, while awareness of the issues raised by this study has been welcomed, policy work in this area remains ongoing.

The NDIS Cultural and Linguistic Diversity (CALD) Strategy 2024-2028 includes a priority area that addresses the need for improving cultural capability amongst staff of NDIS and partners. There is no reference to the need for professional development in cultural competence across the broader NDIS sector. In the context of commissioning SCC services for the specialisation cohorts, an equity-oriented commissioning approach targeting the specialisation cohorts needs to be complemented by stronger directions to the NDIS sector by the regulator, beginning with the NDIS CALD Strategy and extending to all commissioned services to demonstrate how cultural responsivity, safety and competence will be achieved.

Operating models for SCC/SCC+ services (3 models)

Specialist responses and thin markets

The Consultation Paper states that providing SCC services to some participants who require services to be culturally safe and specialised, may mean that SCC providers may need to draw on and access the expertise of existing Disability Representative and Carer Organisations (DRCOs), Aboriginal Community Controlled Organisations (ACCOs), Aboriginal Community Controlled Health Organisations (ACCHOs).

It is concerning that the paper did not include DPOs and key organisations in the CALD/multicultural space, such as NEDA and other expert multicultural and First Nations advocacy organisations, some funded by the Commonwealth and others funded by State/Territory governments for defined advocacy outcomes. In the context of thin markets, cross-collaboration between organisations funded to provide individual advocacy are considered important.

However, it cannot be assumed that these representative and advocacy organisations can respond without additional funding to also provide advisory services to the commissioned SCC and SCC+ service providers. It would likely be necessary to negotiate their inclusion and include their costs as part of the overall proposal submitted for commissioning.

Selecting a delivery model

This table presents three models to meet the SCC service needs of people with disability from culturally, ethnically, and linguistically diverse backgrounds who demonstrate culturally specific support needs.

These models were developed having regard for how each model could ensure as part of its delivery of SCC services:

Key non-negotiables:

Participants’ culturally appropriate choice
Practitioners’ cultural competence
Organisation’s cultural responsiveness

And address consultation questions:

How can the SCC service best support participants who face additional barriers, including those experiencing complex and overlapping support needs or requiring decision-making support?

How can the future SCC model attract, build and retain workforce capability, including retaining participant relationships?

How can the SCC service best support participants in regional, rural and remote areas, or other thin markets, where support options may be limited?

Model	Governance and Operational Management	Workforce
Expansion of existing CALD services delivered by an ethno-specific /multicultural provider to include an SCC service These ethno-specific/multicultural organisations may already be offering a range of health, aged care, social and cultural programs which are not conflicted with other NDIS-funded supports. This model represents expansion of their existing programs to enter into providing SCC services under the NDIS. The provider is run by a recognised CALD community organisation which is supported	These providers already have in place multicultural governance structures, culturally-responsive quality systems, multicultural information and communication systems, culturally appropriate feedback and complaints systems, and knowledge of how to create culturally safe environments for diverse communities. They will likely have existing cross-sectoral relationships and partnerships with other multicultural and with mainstream organisations which have proven themselves to be culturally responsive.	These providers will already have experience in recruitment and management of bi-cultural and culturally competent staff, and have embedded culturally-appropriate practices in engagement and planning with persons from culturally diverse backgrounds.

and trusted by members of the CALD community.

This model may be well-positioned to retain and build upon the exiting specialised workforce capability, and to retain community relationships already in place. | |—|—|—| | The providers in this model may not immediately have expert knowledge and understanding of NDIS processes and of the disability services sector. They may need to recruit NDIS/disability expertise at management level; provide training on NDIS for existing culturally competent practitioners, and expand the existing professional workforce to include appropriately-qualified for the SCC services. | | Co-location of CALD SCC with non-CALD SCC services in urban areas

The CALD SCC may be provided by an established ethno-specific or multicultural organisation. If new to NDIS and disability, the co-location will serve to be a development opportunity.

See section below on Co-location versus integration of CALD and non-CALD services | | The governance body (Board/Management Committee) and/or advisory committees will include representatives from the communities targeted by the SCC services.

If the service co-location evolves into an integrated service model, each of the CALD and non-CALD organisations will bring their own networks, governance and management systems and experience into a shared management environment for shared corporate services.

The integration option may bring greater operational cost efficiencies. | | This model offers opportunities to grow cultural knowledge skills through, for example, shared professional development and communities of practice across CALD and non-CALD SCC services and practitioners. |

This model may unravel in cases where the lead organisation is not ethno-specific or multicultural, and mainstream-oriented systems encroach on areas of CALD management and maintenance of CALD expertise. (For example, when budget pressures arise placing perhaps limits on CALD practice and resourcing)

When CALD and non-CALD SCC teams are co-located it will be important to ensure maintenance of the identity, practices and competencies of the CALD team.

One or more of these providers may already be providing support coordination and specialised support coordination supports under the current arrangements…AND given that some currently registered NDIS providers are providing both support coordination and other NDIS supports including SIL, the removal of conflicted arrangements may prove problematic.

| New consortiums in regional and rural areas bringing together SCC/SCC+ services that reach specialisation cohorts

SCC services reaching across large Statewide, regional or rural areas | | A detailed service agreement will be required to detail the standard of cultural competence which will be maintained as part of the partnership. This may include a clause that states that when a CALD or First Nation’s SCC provider leaves the consortium, another like service must be found as a replacement.

The participation of a specialist organisation as part of the governance and operation of a consortium in itself will not be sufficient. The lead and other mainstream organisations should also be required to demonstrate cultural responsiveness.

Each partner in the consortium will maintain their own governance and operational management systems.

Partners will need to agree on key performance measures and budget for their respective SCC and SCC+ services, noting additional costs which may accrue for practitioners and practices when responding to specialisation cohorts. | | Each organisation providing SCC services as part of the consortium will be responsible for their own recruitment, and professional development of practitioners, although there may need to be mutual agreement on the consistency of qualification levels of practitioners. |

may serve to pull together a number of SCC services.

This model will also allow for consortium partners to be based locationally distant from each other and from the communities they will support. In such unavoidable situations, it will be necessary to ensure through the consortium agreement that organisations committing to outreach services must demonstrate capacity to provide culturally competent services to outreach communities.

Partners will need to demonstrate that they are not conflicted by offering SSC services and other NDIS supports such as SIL.

The questions for this model will be:

how much capacity will be brought into this arrangement to ensure CALD participants will be able to access expert CALD SCC services?
will CALD participants be able to exercise choice and preference for CALD SCC services?

Co-location versus integration of CALD and non-CALD services

Co-location is not the same as integration. Where integrated services may share some corporate functions and management infrastructure and operate in the same or similar manner, co-location acknowledges that there are some clear differences in the operations, staffing and activities of the co-located services. Co-locations can involve placing quite disparate and distinct services under the same organisation/provider, while integration may combine all services into the one operational system. A hybrid may be possible to negotiate. It is important that what is set up as a culturally distinct SCC service for a specialised cohort not be diluted over time, or assimilated into a standardised model of SCC service delivery. Across a number of sectors, co-location has been shown to lead to innovation an thus a co-location as a first step could be expected to evolve over time to something else and better.

Avoiding Conflict of Interest

The potential for conflict of interest where a provider delivers both support coordination and other funded NDIS services and supports are not a new concern. NDIS documentation has addressed this issue since at least 2018. In 2024 the NDIS/NDIA advised registered providers to make all efforts to avoid conflicts of interest through its Position Statement on Conflicts of Interest in the NDIS Provider Market. In this Position Statement it is acknowledges that there are only very limited circumstances

and situations where it may be difficult for providers and participants to avoid a conflict of interest. The “limited circumstances” where a conflict of interest MAY be unavoidable are:

where limited alternative service options are available within regional, rural and remote areas
the services required involve specific cultural and religious choice and practices
highly specialised services where there are few accredited providers operating nationally
the participant chooses to receive supports from a specific provider after fully considering other available services or supports and they formally acknowledge and accept the presence of a conflict of interest with their chosen provider. *

*However, it remains concerning that an exception can be made on the basis of participant choice to enable a conflicted arrangement. Support coordinators and providers, both mainstream and specialist, can occupy positions of considerable influence in these circumstances. In such cases an independent advocate may be able to ensure that the information and options provided to the participant have been based on what is in the participant’s best interests. Safeguards such as this will be required and should be included in the commissioning documentation.

The SCC Consultation paper (Table 3: Overview of key changes that under current arrangements} states “Support coordinators can also provide other NDIS supports.” It’s important to note that a NDIS/NDIA policy to avoid conflict of interest has been in place for some years but it has not been enforced. Table 3 also highlights that under the new proposed commissioning arrangements “SCC services and workers cannot provide other NDIS supports.” This position will not adequately safeguard participants from conflict of interest where providers may also be delivering disability services and supports funded by sources other than NDIS.

The statement in the Consultation paper that “SCC services and workers cannot provide other NDIS supports” appears also to bar workers in an SCC service from working for another NDIS provider. This may be impractical in a NDIS market where qualified workers such as allied health practitioners are in short supply, and where many practitioners may work part time across several providers. Ultimately, this policy position could act as a disincentive to taking up employment in SCC services.

Implications for pricing

CALD participants can require substantially more Support Coordination time in order to understand a plan, what has actually been funded, and what diverse supports or therapies are for. It is also more time consuming for the support coordinator to locate and engage appropriate providers, and to explain language and cultural needs of the participant. NEDA’s member organisations regularly report providing hours of additional support beyond what is funded because the allocated hours simply do not reflect the level of assistance some CALD participants need. This will be the likely outcome for participants from culturally and ethnically different backgrounds and limited English language proficiency who require SCC+ services.

Resource materials in translations should be budgeted as they are required in a number of ethnic communities, not just to inform about the SCC service role and the service options available to CALD participants, but also for materials generally provided to all NDIS participants such as the participant’s rights charter, complaints processes, policies about privacy and confidentiality, explaining service agreements, and how to access the right or preferred interpreter.

Realistically, CALD SCC and SCC+ services may require a different funding formula to allow for the additional time and resourcing requirements when providing services to the three specialised cohorts - CALD, First Nations, and rural and remote communities.

Evaluation of the SCC and SCC+ models

It will be important to build into the commissioning process the structure and capacity to evaluate the establishment and impact of these reforms on:

the broader NDIS system
the commissioned NDIS providers and their workforce
participant outcomes from the SCC ad SCC+ services delivered to all participating persons with disability, differentiating data* for the specialisation cohorts, and having regard for Indigenous protocols in the evaluation.

*The CALD dashboard distributed by the NDIS does not provide information on the percentage of CALD participants funded for support coordination.

Conclusion

The transition to a commissioned model for Support Coordination and Support Coordination Plus presents an important opportunity to address longstanding inequities in access to, and outcomes from, support coordination. An equitable commissioning model cannot assume that equal access to a standardised service will produce equitable outcomes. Participants whose cultural, ethnic or linguistic backgrounds are not adequately reflected in mainstream service systems may require different approaches, specialist expertise, additional time and stronger connections with trusted community and advocacy organisations.

Cultural responsiveness must therefore be embedded in the design, commissioning and evaluation of SCC and SCC+, rather than treated as an additional capability that can be demonstrated through training or representation alone. Specialist multicultural and disability organisations bring expertise, relationships and community trust that should be recognised and appropriately resourced within commissioning arrangements. Where mainstream and specialist organisations work together, those partnerships must provide specialist organisations with meaningful influence over service design and delivery.

At the same time, reforms must preserve genuine participant choice and control. Choice requires more than the presentation of options or formal acknowledgement of a conflict of interest. Participants must have access to information and support that enables them to understand their options, make informed decisions and exercise those decisions free from undue influence. This is particularly important for participants who may face language barriers, unfamiliarity with the NDIS and broader service systems, or other barriers to independently navigating provider markets.

Ultimately, the success of SCC and SCC+ commissioning should be measured not simply by whether services are available, but by whether participants can understand, access and trust those services; exercise meaningful choice and control; and receive support that responds to their individual cultural, linguistic, disability and other intersecting needs. A commissioning model designed around these principles has the potential to strengthen support coordination while ensuring that participants who have historically faced barriers within the NDIS are not further disadvantaged by reform.

Readings

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