Victorian Government submission to the Joint Standing Committee on the NDIS
Inquiry into Market Readiness March 2018
Contents
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Introduction 3
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Establishing the architecture to support market development 4 2.1 The role of the NDIA as market steward 4 2.2 The role of quality and safeguarding on the market 5
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Mitigating and responding to market failure 5 3.1 Market intervention options to address thin markets 5 3.2 Provider of last resort (POLR) arrangements 6 3.3 Managing crises 7
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Ensuring an adequate supply of high quality workers and service providers 8 4.1 The transition to a market based system for service providers 8 4.2 The impact of pricing on the development of the market 9 4.3 Developing the disability workforce to support the emerging market 12 4.4 Home and Community Care Program for Younger People 13 4.5 The provision of housing options for people with disability 14
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Facilitating consumer demand for services 16 5.1 Participant readiness to navigate new markets 16
2 Victorian Government submission to the Joint Standing Committee on the NDIS
- Introduction
The Victorian Government welcomes the opportunity to provide input into the Joint Standing Committee on the National Disability Insurance Scheme (NDIS) inquiry on market readiness for provision of services under the NDIS (the Inquiry).
The Victorian Government is committed to delivering an NDIS which provides people with disability choice and control over their support services. Victoria is at a critical point in its transition to the NDIS and this Inquiry is an important opportunity to address known and emerging market readiness issues.
Effective market stewardship and oversight is essential to ensure participants can access safe, reasonable and necessary supports
Effective market stewardship is essential to ensure that participants can access supports, particularly in rural and regional areas where thin markets are prominent. Building the capability and capacity of the National Disability Insurance Agency (NDIA) and the Quality and Safeguards Commission (the Commission) to improve and oversee the function of markets, will ensure safe and quality services.
Victoria welcomes the NDIA prioritising work on maintaining critical supports
The Victorian Government understands that the NDIA is prioritising work on developing a framework for maintaining critical supports and responding to crises. However, delays have meant that the Victorian Government is resolving crisis situations on the NDIA’s behalf. Victoria welcomes the NDIA actively responding to crises that arise from a lack of provider capability or capacity, and in exceptional circumstances clarification is sought as to how states will be reimbursed for performing this role.
Prices must be sustainable to promote the delivery of high quality and safe services
Adequate prices are integral to facilitating the supply of supports, promoting innovation in the market and ensuring high quality, safe services. Feedback from Victorian stakeholders suggests that the current approach is not sufficient to achieve these outcomes. Victoria welcomes the findings of the McKinsey Independent Pricing Review and agrees with the Productivity Commission’s (PC’s) recommendation to implement independent price monitoring with a view towards reaching independent price regulation.
Development of the disability workforce is a shared responsibility
Ensuring there is an adequate supply of workers with the right skills and values will be a key challenge as we progress towards full scheme and the Victorian Government is investing in workforce skills and development. Victoria would like to work collaboratively with the Commonwealth and the NDIA to ensure investment in the workforce is used efficiently and effectively, and learnings can be applied across Australia.
Victorian Government submission to the Joint Standing Committee on the NDIS 3
Working collaboratively with the NDIA and other jurisdictions will ensure there is adequate growth and supply of high quality housing
There is currently an under-supply of appropriate and individualised specialist disability accommodation (SDA). The NDIA has gone some way to addressing this issue through revising its approach to SDA pricing. However, as the NDIS rolls out, the Commonwealth, states and the NDIA will need to work together to monitor the extent to which SDA pricing addresses supply concerns. 2. Establishing the architecture to support market development
2.1 The role of the NDIA as market steward
Effective market stewardship is essential to delivering a successful NDIS. An effective market will support the independence and social and economic participation of people with disability. There are risks to participants and providers if the NDIA’s capability to effectively steward thin markets in is not in place at full scheme.
The largescale reform of the NDIS requires a proactive market steward, involving:
Collection, analysis and distribution of market information – The PC recommended that the NDIA release market data in a more granular way and at more regular intervals.1 The PC also noted that there is currently insufficient collection, analysis and dissemination of market information to support informed involvement in the market. A steady release of ‘real time’ data will assist providers and participants to make more informed choices.
Creation of broader market infrastructure – Local Area Coordinators (LACs) and the eMarketPlace are essential in building local community capacity and providing timely and useful information to help participants find providers. The Victorian Government would like to see these key components of market infrastructure finalised as quickly as possible.
Bulk purchasing of support services and equipment – This may include proactive arrangements allowing the NDIA to commission services from non-government providers in areas exhibiting limited supply (e.g. regional and remote communities) and at short notice. Bulk purchasing reduces costs to participants and to the scheme and may also provide greater certainty to providers about longer-term demand.
Effective market stewardship must be evidence based
The PC found that ‘market stewardship efforts in the NDIS are hampered by limited and fragmented information and data on the disability support market.’2 Better information and data on the disability support market is therefore crucial to assisting providers to respond to market demand and to promote a better understanding of key market risks and mitigation strategies. In
1 PC Review into NDIS Costs, 2017 (p.36). 2 PC Review into NDIS Costs, 2017
4 Victorian Government submission to the Joint Standing Committee on the NDIS
line with recommendations from the PC Review, the Victorian Government recommends the NDIA and Commission collect and share disaggregated, tailored and forward-looking market data, including provider and workforce data on supply gaps and qualitative information and feedback from market participants.
2.2 The role of quality and safeguarding on the market
According to the PC Review, market oversight is ‘a forward-looking task which involves prudential supervision of the system (including the practices and financial performance of providers), identifying systemic risks and, where possible, taking mitigating action.’3 Market oversight is also essential in ensuring the delivery of safe and quality services to participants.
To facilitate this process, it is essential that the Commission has the capability and mechanisms to share data and information between the NDIA, state and Commonwealth agencies.
Prudential oversight is essential due to the complexities around duty of care and clinical governance for participants with high level disability/complex needs who typically have multiple service providers involved in their care, have very high resource needs and limited care options, and a high probability of breakdown in arrangements.
Victoria considers that the oversight function should focus on providers delivering supports where there are limited substitute providers or supports in a geographic area or market. For example, providers delivering SDA and supported independent living services.
It is also essential that market oversight is balanced against the market development and stewardship functions of the NDIA to enable the market to grow, diversify and succeed. Consideration should be given to the additional administrative and financial burden that oversight compliance places on providers and ensure that they are properly resourced to deliver quality services and meet administrative requirements. 3. Mitigating and responding to market failure
3.1 Market intervention options to address thin markets
There are a number of practical measures that can help mitigate the risk of thin markets. For example, Victoria advocates that in developing the NDIS market, the Commonwealth and the NDIA should identify the opportunities and impact of strategies upon other existing health and social assistance markets, particularly in rural and regional areas. Greater certainty surrounding market intervention is required as thin markets and provider viability could compromise the scheme’s capacity to deliver choice and control for participants.
The Victorian Government has received funding from the Sector Development Fund to build capacity in rural and regional communities and among Culturally and Linguistically Diverse
3 PC Review into NDIS Costs, 2017
Victorian Government submission to the Joint Standing Committee on the NDIS 5
(CALD) and Aboriginal and Torres Strait Islander communities, and to test and promote best practice approaches to working across the interface between the NDIS and key mainstream services. This investment is leading to increased readiness and practical support to interface with the NDIS. However, the Victorian Government is concerned about the capacity of the market to respond in some critical areas as outlined in Attachment A.
The Victorian Government recommends:
that the Commonwealth, NDIA and jurisdictions continue to work together to develop strategies, including identification of early warning signs around emerging thin markets and improving data and monitoring systems to inform future market development or interventions;
continuation of some block funding arrangements to ensure a supply of necessary supports where there are thin markets. Direct commissioning for some services, particularly high cost aids and equipment, may also be more cost effective;
consideration of financial incentives to providers in remote and regional areas where the benefit results in maintaining adequate depth in the provider market and sustainability; and
the NDIA and Commonwealth should consider how the NDIS market interacts with other existing health and social assistance markets in developing strategies to respond to thin markets, such as rural and regional areas.
3.2 Provider of last resort (POLR) arrangements
There is an urgent need to clarify POLR roles and responsibilities
The Victorian Government understands that work is underway to develop a national framework to respond to crises and maintain critical supports, however in the meantime there is an urgent need for clarity of roles and responsibilities.
Without clear POLR arrangements in place, mainstream services are responding to disability related needs beyond their role. For example individuals are remaining in hospital because they have no other accommodation, despite having no specific health needs. Protracted hospital stays can have a negative impact on the health and wellbeing of prospective participants and are putting pressure on hospitals.
Support coordination is key to ensuring that services are an appropriate fit to client needs and support coordinators also have an important role to play in arranging alternative support arrangements for participants in the event of a breakdown in support arrangements. However, the role, definition and accountability of support coordinators for client outcomes under the NDIS .
The NDIS market must have an appropriate depth, diversity and spread to support Victorians with a range of complex support needs and ensure close intersection with other health and social care assistance markets. This will ensure that people with a disability can maximise the benefits of the NDIS and have supports delivered in a holistic and integrated way.
6 Victorian Government submission to the Joint Standing Committee on the NDIS
A POLR must be available for all participants where they are unable to find a provider or where a provider unexpectedly withdraws
The NDIA must be able to directly procure equipment and/or services to make sure participants do not go without support. This will require a short term deployment of resources to ‘buy time’ while longer term solutions can be developed and implemented. The emergence of ‘too big to fail’ providers must also be avoided, which requires strong oversight and regulatory supervision of large disability support providers. Both roles require the NDIA to have a comprehensive local reach, on top of its strong central administration. For example, the Department of Veteran’s Affairs (DVA) ‘non-liability’ DVA cards allows a health service to authorise patients immediate or timely access to a select number of services (ramps, meals on wheels etc.) that have to be in place before the patient is discharged. The remaining supports are worked out over time.
The Victorian Government recommends that:
the NDIA develop its POLR policy and its Market Intervention Framework as a matter of priority and in the meantime provide clarity on interim arrangements;
the NDIA improves training of support coordinators and clarifies their role in the context of supporting participants to identify appropriate providers, mitigating the risk of provider failure; and
the NDIA explores the opportunity for a time-limited ‘block funding’ approach which could ensure that providers are able to offer a POLR function.
3.3 Managing crises
In a crisis, participants’ NDIS plans must be flexible to meet unexpected needs, such as crisis accommodation. In addition, the market place must have clear authorisation to act immediately to coordinate appropriate supports. Without clear processes and authorisation to manage crises, participants will continue to default into mainstream services such as prisons, hospitals, child protection, and in the worst case scenarios, people may fall into homelessness.
Due to the lack of clarity around roles and responsibilities, the Victorian Government has had to step in to resolve crisis situations for NDIS participants. This includes people involved with the health, aged care and criminal justice systems who require critical disability supports to be arranged. For example, recently an NDIS participant was left at a public hospital emergency department by their NDIS provider who was unable to manage the participant’s behavioural issues. While the participant did not have a psychiatric condition, they were admitted to the ward over the weekend as a duty of care response.
In another instance, a state client with complex needs who had prior involvement with the criminal justice system, had their level of support significantly reduced under their NDIS plan. This led to a deterioration of the client’s ability to self-regulate their behaviour, due to functional impairment. This resulted in an assault of a disability worker and the client was remanded in custody, as the NDIA was unable to find suitable accommodation options to meet the complex disability support needs of this individual.
Victorian Government submission to the Joint Standing Committee on the NDIS 7
People with a severe mental illness and associated psychiatric disability often experience frequent or periodic relapse in their mental health condition, resulting in a significant reduction in their psychosocial functioning and the need for a rapid escalation in their psychosocial support. In these situations, if the person does not receive timely access to the right type and level of psychosocial support, they may be at heightened risk of experiencing a psychiatric crisis. Over time, frequent relapses may increase the severity of their psychiatric disability.
Victoria considers that a psychiatric crisis should necessitate an immediate escalation of supports and an urgent review of the participant’s plan, particularly if the person is at risk of suicide, self-harm or has attempted suicide.
The Victorian Government recommends that:
the NDIA plays a more active and responsive role in responding to crises that arise from a lack of provider capability or capacity. This would require a rapid response capability after business hours and on the weekend;
the Commonwealth clarifies how it will reimburse states for performing this role on the NDIA’s behalf if it is unable to perform the role adequately; and
the NDIA should work with jurisdictions to develop respective roles and responsibilities for mainstream services in managing a range of foreseeable crises. 4. Ensuring an adequate supply of high quality workers and service providers
4.1 The transition to a market based system for service providers
Providers face significant challenges adjusting to the new environment and changed funding arrangements
The transition to a market-based approach is dramatically changing the way disability service providers operate. The evolution from a predominately block-funded system to one based on individual payments and consumer choice and control carries with it a risk of disruption to service providers and their clients. Further, the demand for disability services is set to increase exponentially from 220 000 to an estimated 460 000 service users, once the full scheme is in place.
Under the new fee-for-service delivery model providers bear increased financial risk, for example for non-payment and late payment, and in turn may have a greater need for cash reserves. According to research from National Disability Services (NDS), two-thirds of providers surveyed reported less than the minimum recommended cash flow standard of three months or more of spending reserves. A number of disability service providers are also carrying the costs
8 Victorian Government submission to the Joint Standing Committee on the NDIS
of continuing to provide supports when a participant plan expires and no new plan has been put in place.4
Further, issues with the NDIS payment portal have also led to delays in service bookings and disruption of cash flow for providers. Payments to providers must be timely so as not to disrupt the supply of disability supports. It is also essential that the NDIA is equipped with sufficient capacity and capability to run an effective provider portal and put in place effective support systems to reduce the administrative burden on providers.
Victoria is doing its part to prepare providers for the NDIS and increase the capacity of disability support organisations through its $20 million investment in its Transition Support Package. In addition, providers funded by the Victorian Government and transitioning to the NDIS have been assisted with streamlined NDIS registration, and over 100 new providers have been approved to deliver supports in scope of the department’s quality and safeguarding requirements. Victoria has also produced communication materials for service providers to assist in their understanding of transitional quality and safeguarding arrangements.
Greater clarity and investment in Information, Linkages and Capacity (ILC) building activities is essential to support provider transition
Greater transparency on the types and range of supports funded under the ILC is critical for providing assurance to people with disability that they will receive an equitable share of the funding and for providing support to providers in transition, particularly smaller user led services, to prepare for ILC commissioning in 2019.
Of equal importance is how the ILC will be implemented, including the type of delivery arrangements that will be funded and the associated risk of funding low scale fragmented activities. The Victorian Government is concerned about the short-term grants model for ILC commissioning. To effectively build capacity in the community and mainstream services the NDIA will require a longer term view, with coordinated planning to ensure long-term outcomes are realised.
Finally, given the important benefits ILC activities will generate, and in line with recommendations from the PC Review, the Victorian Government considers that the current level of committed ILC funding is inadequate.
4.2 The impact of pricing on the development of the market
NDIS prices must reflect a reasonable cost for delivering quality services. There is a balance to be struck between prices that are too high – discouraging providers from becoming more efficient as they move away from block funding – and too low, where providers are unable or unwilling to provide services at all.
Insufficient NDIS prices can result in significant financial pressure on service providers, putting them at jeopardy of market failure or compelling them to compromise the quality or safety of
4 State of the Disability Sector Report 2017
Victorian Government submission to the Joint Standing Committee on the NDIS 9
their services . Consequently, if there is an undersupply of disability services, this risks compromising choice and control for participants. Sufficient prices are therefore essential to ensuring innovation in the market and the delivery of safe and high quality services.
While the benefits of activity based price structures are well known, these structures should also recognise the higher cost of service delivery for providers operating in niche and other smaller volume markets. Victoria recognises that the NDIA has introduced a price loading for remote and very remote supports, however this loading has limited application in Victoria.
The ability of existing service providers to properly recover costs (fixed and variable) is critical to market sustainability in the shorter term and long-term market expansion. For smaller volume service providers operating in niche or rural markets, `there is a significant risk that the funding will be insufficient to ensure comprehensive costs are recovered and to ensure continued sustainable operations’.5
Many of the current challenges faced by the NDIS in transition can be partially attributed to poor NDIA pricing including:
underutilisation of plans- in some instances participants are unable to utilise all of the committed supports in their plan due to an undersupply of disability services. This is particularly the case for participants living in regional or remote areas;
thin markets- for example where providers are unable to provide services in those markets because NDIS prices do not take into account the real cost of service delivery;
potential gaps in workforce supply-in some cases insufficient NDIS prices are deterring skilled workers from the disability sector resulting in gaps in workforce supply ; and
poor participant experiences for people with complex needs- existing pricing structures for people with complex needs are insufficient and do not take into account costs for the multiple factors that impact on the support requirements of clients with complex needs.
Prices that reflect the actual costs of delivering high quality services are thus vital to ensuring that the scheme is sustainable and able to deliver on its original objectives.
The NDS 2017 State of the Disability Sector Report found that two-thirds of providers are concerned that they will be unable to provide services at NDIS prices.6 Consistent with this, Victorian stakeholders continue to raise concerns about NDIS prices (Attachment B).
There is a strong link between price setting and market stewardship
As a market based service system, prices are an important lever to address thin markets and potential gaps in workforce supply.
However, the current pricing approach appears to be exacerbating these market failures, adopting a one size fits all approach. For example, the PC highlighted that the loading for
5 A National Costing and Pricing Framework for Disability Services, National Disability Services and Curtin University, 2014 p. 26 6 State of the Disability Sector Report 2017
10 Victorian Government submission to the Joint Standing Committee on the NDIS
complexity of needs is based on average costs, which as shown in the figure below, is often inadequate.
The Victorian Government recommends that the NDIA adopt a more dynamic pricing system that sets out how prices fluctuate in response to a thin market, varied levels of need (rather than just an average) and/or signs that workforce growth is not keeping up with demand.
Figure 1: Indicative analysis of impact of the single complexity loading7
3.5 Price offered by the NDIA True cost of support (dependent on complexity)
3.0
The single loading for complexity
can lead to prices that exceed
2.5 the cost of providing services for
less complex needs...
2.0 index
1.5 Cost
1.0 ...but can also lead to levels
where the price is less than the
0.5 cost of providing services for
more complex needs.
0.0
1 2 3 4 5 6 7 8 9 10 11 Complexity12 13 14of needs15
Price setting must be independent and reflect the real cost of service delivery
Adequate prices must be set to encourage the supply of supports and promote competition and innovation in the market. Feedback from Victorian stakeholders suggests that the current approach to pricing is not reflective of the true cost of service delivery.
Consistent with recommendations from the PC Review, the Victorian Government recommend a two staged approach to pricing:
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the establishment of an independent price monitor, in the short term, to validate the NDIA’s price setting in transition; and
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in the longer term, a transfer of the NDIA’s pricing powers to an independent body, given that the conditions for full price deregulation require further development.
The establishment of an independent price regulator will give providers and participants certainty and transparency about pricing. This in turn will encourage new and existing providers to supply quality disability services and supports to meet the individual needs of people with disability.
Victoria welcomes the Final Report from McKinsey and Company’s independent pricing review and looks forward to working with the NDIA to implement its recommendations.
7 PC 2017, Final Report, p. 309
Victorian Government submission to the Joint Standing Committee on the NDIS 11
4.3 Developing the disability workforce to support the emerging market
The disability workforce will need to grow significantly to meet the demand for disability services under the NDIS. The NDIA’s 2016 market position statement predicted that the Victorian disability workforce will need to grow by approximately 76 per cent in order to meet the projected growth in demand over the next three years. Supply concerns are particularly evident in rural and regional Victoria, where there is increasing demand for allied health services and supports for people in crisis situations.
The Victorian Government is investing in workforce readiness activities
In October 2016, the Victorian Minister for Housing, Disability and Ageing released Keeping our Sector Strong: Victoria’s workforce plan for the NDIS (the Plan). The Plan is supported by a $26 million investment, that will fund a range of workforce development, training and skills initiatives to promote the growth and development of the disability workforce in Victoria.8
The Plan comprises nine workforce priorities focused on building the disability workforce of the future to meet the needs of the NDIS and achieve the best possible outcomes for people with disability.
There is a risk that the disability workforce will not be sufficient to meet expected demand
The PC Report found that the overall scale of workforce growth required, combined with challenges of worker roles and regional variation, means that the disability workforce will be insufficient to meet the demand for services at full scheme. More needs to be done to attract and retain workers in the disability sector and to upskill existing social services workers.
To complement the work that Victoria is undertaking to develop the workforce, the Victorian Government recommends that the Commonwealth lead national workforce activities and develop a comprehensive approach to tackle supply and demand challenges, for example:
actively promoting growth in the sector through a national workforce campaign;
considering innovative ways to increase disability workforce in regional and rural areas;
coordinate workforce development initiatives between different jurisdictions to leverage the expertise of all states and territories;
facilitating greater sharing of data and information between the NDIA, the Commonwealth and providers to ensure workforce development opportunities are aligned. For example, the PC recommended that the Commonwealth Government fund the Australian Bureau of Statistics to collect policy-relevant data on the disability care workforce;
facilitating greater sharing of its workforce growth and quality initiatives, with a view of complementing already established state projects (i.e. outcomes from Commonwealth’s Sector Development Fund projects and Care Workforce Regional Coordinator Initiative);
8 $4.88m of which is funded by the Commonwealth Sector Development Fund
12 Victorian Government submission to the Joint Standing Committee on the NDIS
leading the development of a coordinated response to meet the demand for allied health services and appropriate alternatives by working with professional bodies, tertiary institutions including Universities Australia, and the Commonwealth Department of Health;
monitoring the emerging workforce policy issues, including the potential impact of the Fair Work Commission’s review of the Social Community Home Care and Disability Services award on pricing arrangements and the ability of the NDIS to attract a sustainable supply of workers in an increasing competitive market; and
engaging with states to ensure that regional differences are addressed and learnings applied across all jurisdictions; and ensure specialist NDIS workforces are prioritised and sustained.
To facilitate this work, the Commonwealth Government could leverage the expertise of the Market Oversight Working Group (MOWG), a sub working group of the Senior Officials Working Group. In the first instance, MOWG could develop a structured forward looking approach to national workforce activities, which complements the work and functions of the Australian Industry Skills Committee.
4.4 Home and Community Care Program for Younger People
The Home and Community Care Program for Younger People (HACC-PYP) provides services and supports to people under 65 years old to live as independently as possible within the community. In Victoria, local government has historically been a key provider of community care services under the HACC-PYP program. At full scheme, there will be an estimated 10,000 local government HACC-PYP clients who will be eligible for the NDIS.
Anecdotal evidence from individual Councils and the Municipal Association of Victoria suggests that most Victorian councils do not intend to register as NDIS providers. For example, in North East Melbourne and Central Highlands, only 30 per cent of providers who previously delivered support under the state system are registered for the NDIS. Almost all of these providers delivered HACC-PYP supports. One of the central drivers impacting the decision of councils not to register as NDIS providers, is the discrepancy between NDIS prices and the true unit cost of service delivery (in particular domestic assistance, personal care and respite).
In order to facilitate the smooth transition of eligible HACC-PYP clients to the NDIS, the Victorian Government has agreed with the NDIA that the transition will be on an in-kind basis. However, these measures are not intended to last beyond transition. Given, a majority of councils have indicated that they do not intend to register as NDIS providers, the Victorian Government is concerned that this will create a gap in the market for rural and remote areas. For example, where alternative providers may not be available, or prepared to deliver personal care to people living in these municipalities.
The Victorian Government therefore urges the NDIA to implement NDIS prices which reflect the true cost of service delivery. The Victorian Government is leading work to map and identify current HACC-PYP clients that are likely eligible for NDIS but live in more remote areas and is seeking engagement from the NDIA to identify potential areas of risk so the NDIA can
Victorian Government submission to the Joint Standing Committee on the NDIS 13
effectively implement mitigation strategies. In the event that councils do not register to provide services under the NDIS and will be providing this information to the NDIA.
The Victorian Government recommends that the NDIA examine pricing arrangements for HACC-PYP to ensure they reflect the true cost of service delivery. Where necessary, the NDIA should partner with councils to support participants to find alternative registered providers.
4.5 The provision of housing options for people with disability
Specialist Disability Accommodation
In Victoria there is currently an under-supply of appropriate and individualised SDA and this undersupply is predicted to intensify as the demand for housing increases under full scheme NDIS.
At full scheme it is estimated that approximately 6,300 NDIS participants (six percent of all NDIS participants) will require an SDA response. The remaining 94 per cent of NDIS participants will continue to access housing through social housing and the private market. The availability of individualised support under the NDIS is expected to increase demand for housing assistance, which includes additional housing support, as well as social and affordable dwellings that enable people with a disability to live independently.
The Victorian Government welcomes the development of benchmark pricing and payments for SDA. The SDA ‘cost of capital’ pricing approach will provide an opportunity to grow supply over time and stimulate more innovative specialist accommodation options for people with disability. As the NDIS rolls out, the Commonwealth, states and the NDIA will need to work collaboratively together to monitor the extent to which SDA pricing, together with the application of the NDIS SDA Rules 2016, deliver on this expectation.
The development of strategies to stimulate SDA market development and more innovative housing solutions is a priority for Victoria. The Victorian Government is working closely with the NDIA and two national organisations, the Summer Foundation and Young People in Nursing Homes Alliance, who both have long standing missions to improve life outcomes for young people residing in, or at risk of, residing within residential aged care. This work will see published demand data on people with disability that require NDIS funded SDA. This data will be crucial in the development of support profiles to stimulate new SDA capital development, whereby lenders and developers can model investment opportunities and mitigate revenue risks.
Housing assistance in Victoria
People with a disability are highly represented in social housing, partly because of limited options and discrimination in the private rental housing market. Housing assistance in Victoria is prioritised for disadvantaged people. Public housing aims to provide housing to those with an urgent need, plus other complex needs and barriers to housing, such as disability.
Homes for Victorians commits $799 million in additional homeless and housing support and $2.1 billion in financial instruments to deliver around 6,000 social housing dwellings over five
14 Victorian Government submission to the Joint Standing Committee on the NDIS
years including new builds, subsidised rentals and renewal of up to 2,500 ageing public housing properties through initiatives such as the Public Housing Renewal Program.
In order to streamline the application and allocation processes for social housing, the Victorian Government has developed an online Victorian Housing Register. This consolidates all social housing waiting lists into a single register. The register will improve the service provided to clients, including those with a disability, seeking housing by enabling access to a broader range of social housing options.
To ensure that social housing is directed to those most in need, community housing agencies will be required to allocate up to 75 per cent of their social housing vacancies to priority applicants on the register.
The Director of Housing has guidelines in place for the development of new social housing properties to achieve: better apartment design standards for all dwellings (which specifies that 50 per cent are accessible) and the standard of Gold level of the Liveable Housing Design Guidelines to ensure social housing is constructed to readily meet the needs of residents who may require accessible accommodation. The Better Apartments Design Standards were introduced in April 2017 and include requirements for at least 50 per cent of new apartments to include design features that meet the needs of people with limited mobility.9
The Victorian Government recommends that the Commonwealth considers these strategies at a national level.
People with psychosocial disability are experiencing housing stress
The Victorian Government is concerned that many people with a psychosocial disability are experiencing a housing affordability and shortage crisis, due to the high demand for social and public housing and rising rents and falling vacancy rates in the private rental market. For those on low incomes there are limited private rental dwellings available which allow people to spend less than 30 per cent of their income on rent, particularly in urban areas.
It is difficult for people to manage their psychosocial disability and move towards sustainable participation in the social and economic life of the community when they are homeless or living in substandard accommodation. Failure to address this systemic issue will impact on the sustainability of the NDIS.
The Victorian Government recommends that:
the Commonwealth work with Victoria and the NDIA to monitor impacts of SDA market gaps on mainstream social housing;
the Commonwealth work with Victoria and the NDIA to develop responses that address housing poverty experienced by NDIS participants;
the Commonwealth and NDIA determine the arrangements in place post 2019 for Young People in Residential Aged Care post 2019 and Residential Aged Care providers in regard to accommodation fees and whether they can register as SDA providers; and
9 https://www.planning.vic.gov.au/policy-and-strategy/planning-reform/better-apartments
Victorian Government submission to the Joint Standing Committee on the NDIS 15
the NDIA releases data about the participants requiring SDA and their needs and preferences. This is urgently needed to support the development of new SDA. 5. Facilitating consumer demand for services
5.1 Participant readiness to navigate new markets
Choice and control is increasing for some participants under the NDIS
There are early signs that choice and control for some people with disability is increasing under the NDIS. For example, in North East Melbourne, prior to the introduction of the NDIS, there were approximately 600 clients who were self-managing their disability support. As at October 2017, this number had increased to around 2,600 clients.
Participants are enjoying the benefits of the NDIS. For example, NDIS plans in North East Melbourne have been approximately 180 per cent higher (on average) than the funding received under the state system.10 This additional funding will increase the level of choice to be made as clients implement their plan. However, NDIS participants are not taking full advantage of all of their plan funding. This may be, at least in part, driven by participants not yet being able to fully navigate new markets.
People with mental health and psychosocial disability are more likely to report less choice and control since becoming an NDIS participant
People with complex needs, psychosocial disability and those that are hard to reach are experiencing NDIS access issues, as evidenced by the high number of plan cancellations and relatively low rates of access in Victoria. Victoria considers that greater specialisation of planners as well as individualised gateways/outreach is required.
The Victorian Government acknowledges that the NDIA is working to implement a range of improvements, including tailored approaches for people with complex needs, through their new pathways approach.
Preparing participants to navigate the NDIS
Pre-planning plays a significant role in ensuring participants are informed and empowered to navigate the new NDIS market place. Victoria is concerned that insufficient effort has been directed to pre-planning for participants and LACs have not been able to engage in essential work to provide participant and community development during the pre-planning stages. In line with recommendations from the PC, the Victorian Government recommends that LACs are in place six months in advance of roll out to prepare participants as they transition to the NDIS.
In Victoria, intermediary services have helped to encourage participants to self-direct and self- manage their supports. However, under the NDIS only 11 per cent of participants in the
10 DHHS to provide source
16 Victorian Government submission to the Joint Standing Committee on the NDIS
transition period are taking advantage of intermediaries.11The Victorian Government supports the PC recommendation that ‘the NDIA should provide more information to participants and planners about the roles and use of intermediaries.’12
Advocacy
Access to advocacy is a critical element for participants in exercising choice and control. The Victorian Government has noted increased demand for advocacy associated with the NDIS rollout. Access to advocacy is also fundamental in promoting the rights of all people with disability accessing mainstream services such as health, housing, education and transport. Over time this will reduce pressure on the NDIS by increasing the independence of people with disability and reducing barriers to social and economic participation.
Victoria funds a range of disability advocacy and self-advocacy organisations including the Victorian Disability Advocacy Program. This program receives around $3 million each year for 24 disability advocacy organisations. The program includes funding for the Self-advocacy Resource Unit and the Disability Advocacy Resource Unit. The Victorian Government encourages other jurisdictions to match Victoria’s commitment through additional funding for advocacy to build the scheme as intended.
The Victorian Government recommends that:
The NDIA implements tailored approaches to engaging with participants, particularly complex clients and people with a mental illness;
a greater emphasis is placed on pre-planning, in-depth planning conversations and plan quality reporting;
LACs are on the ground six months ahead of scheme roll out;
the NDIA partners with Victoria to complete a review of the operation of LAC during the roll out phase to assess its effectiveness and make any required adjustments to the model;
other jurisdictions match Victoria’s commitment through additional funding for advocacy; and
the NDIA encourage the use of intermediaries where appropriate, by providing more information to participants and planners about their roles and use in assisting participants to navigate the NDIS.
11 PC Review into NDIS Costs, 2017 12 PC Review into NDIS Costs, 2017
Victorian Government submission to the Joint Standing Committee on the NDIS 17