Submission to Senate Community Affairs

Legislation Committee

Response to the National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No.1) Bill 2024

disability advocacy nsw | website: da.org.au | email: da@da.org.au | phone 1300 365 085

About Disability Advocacy NSW (DA)

DA has over 35 years of experience providing individual advocacy to all people with disability of any age. The organisation services over two thirds of NSW, making it the largest individual advocacy disability organisation within NSW.

Since the inception of NDIS in 2013, much of the individual advocacy support we have provided to clients has been in relation to NDIS.

While DA has a presence in Sydney, it has a strong commitment to regional, rural, and remote (RRR) areas in NSW. With local disability advocates on the ground in Armidale, Bathurst, Broken Hill, the Blue Mountains, Coffs Harbour, Dubbo, Newcastle, Northern Rivers, Port Macquarie, Tamworth, and Taree, the service has ongoing exposure to the lived experiences of people with disability and their families living in these areas.

DA’s systemic advocacy draws on coalface information from clients, disability advocates, and the disability sector more broadly to identify and address emerging policy issues. We have written at length about the various issues faced by the many people with disability who live in RRR communities and areas, including issues relating to thin markets, limits to participant choice and control, and entrenched inequality.

For further information we invite the committee to view our research reports at www.da.org.au/resources.

If you have any questions or comments regarding this submission, please contact:

Amanda Brickwood Executive Officer – Disability Advocacy NSW E: M:

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Summary and Recommendations

DA welcomes this opportunity to provide feedback on the Bill.

The changes proposed in the Bill would be the most significant change to the framework of the NDIS since its inception.

da is concerned that many aspects of the bill are inconsistent with the sequenced approach recommended in the Final report from the independent review into the design, operations, and sustainability of the ndis (ndis Review), and several proposed changes are likely to negatively impact the participant experience – especially for participants with complex support needs (including those with multiple disabilities, psychosocial disabilities, and participants with cognitive and intellectual disability). The proposed changes would limit the scope of supports funded under the ndis at a time when there is no alternative ecosystem of supports available outside the ndis.

We also think the proposed changes will negatively impact those living in rural, regional, and remote areas (RRR), for whom entrenched inequality and ‘thin markets’ is an ongoing reality.

Our view is that careful consideration and further consultation is required to ensure the government’s response to the ndis review appropriately addresses the significant issues identified and does not create additional layers of complexity, bureaucracy, and unfairness in how the ndis operates.

we are confident that the senate community affairs legislation committee would agree with us that it is vital for planners, designers and consultation processes operating in the disability space to: o prioritise safety, trust, and transparency o ‘consider both the intended and unintended impact on people with disability’ o ‘make sure people remain safe - physically, mentally, culturally, and psychologically.’

our submission focuses the following key concerns we have about the bill:

The timing of the Bill and the lack of consultation and co-design.
The proposed introduction of a compulsory needs assessment to determine plan budget, where the assessment is limited to assessing impairments for which access is met (and is therefore not a ‘whole of person’ assessment).

The creation of new categories for distinguishing what is and isn’t a NDIS support which are difficult to interpret, and which are proposed to be introduced before alternative systems of support are in place outside of the NDIS.

The proposed increased information gathering powers of the National Disability Insurance Agency (NDIA) and powers to suspend access to supports (via the suspension of plan funding) where participants fail to comply with information requests within a prescribed timeframe.

Recommendations

We do not think the NDIS Bill should be legislated in its current form.

We consider the government should instead start with a full response to the NDIS Review report including:

- a clear response to the suggestions about prioritising the implementation of certain recommendations in the short term,

- a roadmap for implementing its response to the recommendations of the NDIS Review,

 - details of the entire package of legislative reforms proposed.

Before significant changes to the framework of NDIS are legislated, the government should:

provide clarity as to what disability supports will be available outside of NDIS plans, including through foundational supports and state-funded disability support.

provide full detail of the proposed changes, and real and meaningful opportunity for people with disability and advocacy organisations to provide feedback and contribute to the design of changes,6 especially in relation to:

 i. the types of supports the NDIA intends to ‘rule in’ or ‘rule out’ as NDIS supports,
  ii. any proposed needs assessment process, including who will conduct the assessment, the assessment tool that will be used, and whether needs assessments will be reviewable decisions.

We echo and agree with comments made at page 269 in the Final Report: Working together to deliver the NDIS (Final Report NDIS Review), 2023 about the consequences of ’insufficient design with people with disability and the sector, a lack of consultation with independent experts, and inadequate testing. We note that the Review report encourages ‘a five-year transition period, robust design and testing with people with disability, and a focus on retaining the features of the NDIS that are working well and replacing those that are not.’

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Timing of the Bill and lack of consultation and co-design

DA is particularly concerned about the speed with which this Bill has been introduced and the lack of

consultation and co-design that has occurred with people with disability and peak advocacy and legal

bodies in relation to the proposed changes and the potential impact on NDIS participants.

Also, the bulk of the detail about the proposed changes will be established by delegated legislation;

ules and methods which have not yet been shared with the public. Understanding what the proposed delegated legislation will look like is vital to understanding how the proposed changes under the Bill would impact the disability community, particularly those currently relying on NDIS supports that may be excluded under the new framework.

The context in which this Bill has been tabled is important.

The government’s full response to the various findings and recommendations from the NDIS Review is still pending. Similarly, a full response to the Final Report from the of the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability is yet to be provided. This is expected by mid-2024.7

Additionally, we wish to emphasise the following statements made in the NDIS Review report:

‘Our recommendations must be considered and implemented as a package over a five-year transition period. During this period, implementation should be sequenced strategically to

address critical dependencies, manage risks, and mitigate or minimise disruptions for
```
 participants, providers, and workers.
```
Implementation of some recommendations should be prioritised in the short-term to make

immediate improvements to the participant experience, such as foundational supports (see

Recommendation 1), updating guidance for making access requests (see Action 3.2) and
```
strengthening the workforce (see Recommendation 15).

For more complex recommendations, a staged transition approach will be necessary to allow
    for more substantial consultation, design and testing prior to a phased roll-out.’ 8
```

7 Department of Social Services, Australian Government Progress Update on the Disability Royal Commission, 2023 ,p.12 indicates that ’The Government will release a formal response to the NDIS Review in 2024. 8 Final Report: Working together to deliver the NDIS (Final Report NDIS Review), 2023, p. 270.

‘First and foremost, investments are needed in foundational supports and in making mainstream services more accessible and inclusive. These will reduce pressure for NDIS support. It will also create a fairer and better system of support for all people with disability.’
‘Changes to access and budget setting processes can only be implemented once the recommended foundational supports are in place to offer support outside the NDIS (see Recommendation 1).’
‘The Department of Social Services, with input from the National Disability Insurance Agency and NDIS Quality and Safeguards Commission, should review the recommendations from this Review and develop a proposed package of legislative reforms’ (Action 25.1).
‘National Cabinet should agree and publish an implementation roadmap’ (Action 26.1).

The proposed Bill aims to give effect to recommendation 3 of the NDIS Review Report, as well as the interconnected elements in recommendations 5, 6 and 7, and support the partial implementation of recommendation 17 of the NDIS Review Report. However, this Bill seeks to implement these changes before earlier foundational changes recommended by the NDIS Review have been developed. No roadmap or detail has been provided about other recommendations including the introduction of foundational support and clear agreement between the Commonwealth and the states as to the nature of disability supports to be provided outside of the NDIS.

There has been a lack of open dialogue with the disability community about the government’s interpretation and response to the NDIS review before introducing legislative reform that will significantly change and impact participant experience.

Knowing what supports will be available outside of the NDIS is essential to understanding the potential impact of the proposed changes. An example is the change proposed by s 10 of the Bill, which would significantly limit the scope of supports available under the NDIS. This is a key concern of disability advocates:

“The changes to narrow the scope of the NDIS need to “I am concerned that changes will potentially be be complemented by made to the system before the whole framework has ‘foundation supports’ which been revealed or even possibly planned. It is already would allow people to very hard for people to try and navigate the access access help they need, to requirements for the NDIS.” without feeling their only option is the NDIS.“

If the proposed changes to limit NDIS support are introduced now, participants who are currently reliant on specific reasonable and necessary supports may receive a more limited plan budget that offers less funding overall (and therefore less support), less choice and control over the supports they can spend this funding on, and no alternative avenues for accessing those ‘lost’ but necessary supports. This is likely to particularly impact on participants with complex support needs, and the thousands of consumers of disability supports who live in RRR areas and who already face entrenched inequality and limited to no choices when attempting to access supports due to thin markets.

The introduction of a compulsory needs assessment, where assessors would only assess impairments which meet the disability or early intervention criteria.

DA is concerned about the proposed introduction of a compulsory needs assessment which is specifically not conducted on a whole person level. We are concerned that this will result in assessments which provide an inaccurate or incomplete understanding of a person’s disability related needs and therefore an increased number of incorrect and unfair planning decisions.

Concerns about part-person assessments

A key recommendation of the NDIS Review was to remove the label of disabilities and focus on functional impairment at a ‘whole person’ level based on support needs and intensity rather than impairments when determining a participant’s support budget.

However, the proposed Bill adds, via s 34(1)(aa), the following requirement in relation to NDIS supports: “the support is necessary to address needs of the participant arising from an impairment in relation to which the participant meets the disability requirements (see section 24) or the early intervention requirements (see section 25)”, (emphasis added).

Also, the proposed s32L requires that needs assessments are limited to only those impairments which the National Disability Insurance Agency (NDIA) decides meet either the disability or early intervention criteria.

These changes appear to contradict Minister for the NDIS Bill Shorten’s assurances that “needs assessment will look at your support needs as a whole – and we won’t distinguish between primary and secondary disabilities any longer.”

C Baylosis and D Woods. The Aussie Battlers: Life with a disability in regional, rural and remote NSW, DA Scoping Research Report, 2023.
Final Report NDIS Review, p. 92. (Action 3.3).
NDIS Amendment (Getting the NDIS Back on Track No. 1) Bill 2024 - Second Reading Speech, Hon Bill Shorten MP, March 2024.

This also is despite the NDIReview report recommending to focus on functional impairment at a ‘whole person’ level

This also is despite the NDIS Review report recommending to focus on functional impairment at a ‘whole person’ level, stating that: “…focusing on the whole person, their circumstances and their support needs would also end the current unhelpful and inappropriate focus on establishing a primary or secondary disability.” We also note the recommendation of the Joint Standing Committee on the National Disability Insurance Scheme “that the National Disability Insurance Agency assess people according to the totality of their disabilities and no longer require participants to nominate a ‘primary disability’ and ‘secondary disability.’”

But the issues with these proposed changes go further. Where the Bill would legislate a new requirement for a support to be linked to an impairment that meets either the s24 disability or s25 early intervention requirements, it does not provide any mechanism for participants to meet this requirement, other than at the time of access. There is no process for identifying, assessing, determining, and communicating to participants how many of the person’s impairments meet the requirements. There is no process for enrolling new impairments if they arise.

Under the current NDIS Act, a person applying to access the scheme is only required to have one impairment that satisfies either all the s24 or s25 criteria in order to become a participant. The Act does not require the decision maker to undertake further assessment of other impairments once a person becomes a participant or require a participant to have any new impairments reassessed against the access criteria. Despite this, the fact that a disability is not listed as a ‘primary disability’ or was not considered when accessing the scheme is frequently cited by the NDIA as justification not to fund support related to that disability. This appears to be a creation of NDIA policy rather than law which continues to be applied despite numerous decisions of the Administrative Appeals Tribunal (AAT) rejecting this approach.

If a requirement is introduced that needs will only be assessed (and supports must be linked to) the impairment that meets the access requirements, the frustrations and difficulties that have plagued the scheme for years in relation to ‘primary disabilities’ and getting proper acknowledgement of other disabilities and impairments will only be compounded.

Participants with multiple and complex disabilities (of which there are many) will be disproportionately disadvantaged by this change. Effectively, they would be required to re-apply for access for each disability they live with, to ensure they can access funding and support in relation to each impairment. This will likely be very time-consuming and confusing, and if a participant is required to obtain additional reports or assessments to prove eligibility for each impairment it will likely be very expensive too.

will create complexities where a support need relates to a combination of impairments some of which have met the disability or early intervention criteria and some of which have not.

These concerns are echoed in feedback from our disability advocates in response to this change:

“This  is already the functioning position of NDIA        “A lot of current participants have
representatives.  It  fails to address the needs  of             not been notified which
persons as complex, with many, varied and often over-        impairment they have met access
lapping co-morbidities and places an unfair onus on                                                                    on, as it's not communicated in
he participant to be able to explain this distinction,                                                                    the 'access met' outcome letter.
while also encouraging that person's treating team to
                                                                         Will there be sufficient timing for        consider and communicate their needs in a less
          holistic way.”                                                    participants on the scheme to
                                                        have the opportunity to add
                                                           these? Can they even do this?”

“Will the NDIA be determining and communicating to all current and new participants which of
their impairments meet the criteria and so are ‘assessable’ by the need's assessor? What
 happens when there’s a disagreement about whether one or more impairment meets the
criteria? Is there a limit to the number of impairments that can meet the criteria? If so, why?
And what is the process to ensure that when impairments worsen or new ones arise, the
person can access the additional support they need in a timely way? re decisions made by
NDIA in relation to which impairments do/don’t meet the access requirements reviewable? Are
neds assessments reviewable? These and so many other questions are not addressed by the
proposed legislation in its current form.”

We do not think that the participant experience will be improved by the introduction of a requirement

that support needs will be determined based on a part-person assessment of a person’s disability

related needs. And we do not think the original intent of the scheme was to limit support for people with

complex and multiple disabilities. The changes are unhelpful, confusing, and not compatible with a

whole of person understanding of disability and will lead to an increase in disputes and requests for

funding reviews.

Lack of information about the proposed needs assessment model

There is a lack of clear information as to how the proposed needs assessment will be used to decide

the total budget of support provided in the participant’s plan and what other information will be

considered.

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S32L(2) of the Bill requires the use of an assessment tool for needs assessments.

However, as the assessment tool has not been determined, there is no opportunity to consider the suitability of this tool when providing a response to this Bill.

Based on current information, we are concerned that the funding ‘output’ from the needs assessment will involve the use of algorithms and will be formulaic, putting people into funding categories based on labels rather than providing a plan that is responsive to individualised needs on a whole person level.

Participants and advocates fear that the proposed needs assessments will amount to ‘independent assessment 2.0’ or ‘robo-planning’.

Further explanation is needed about how the assessment tools will create a budget that is truly individualised and needs based. Particularly participants with multiple, complex and/or lesser-known disabilities would be disadvantaged by an assessment model that is not responsive or flexible to individual needs.

It appears the intention of the legislation is that the opinion of the needs assessor would be determinative of the funding in the support budget. The role of the participant and their allied health professionals/ treating specialists as the best sources of information about functional impairment, support needs and individual circumstances would potentially be diminished. It is uncertain how any information provided by the participant or their allied health professionals and specialists will be used by the needs assessor to inform the outcome of the assessment and the participant’s final budget.

A theme reflected in the feedback from disability advocates is that participants will be disadvantaged if the assessor making recommendations lacks the necessary qualifications or understanding of the person’s disability:

e.g. someone with a mental health background conducting them for psychosocial disability?). Will the needs assessment be a reviewable decision? What if the needs assessment outcome contradicts the recommendations of a person’s current support network who know and understand the participant’s needs the best? What if the assessor is not skilled in assessing conditions where participant has reduced insight into extent of their needs or is high-masking and appears ‘functional’ and support needs are not as visible? Will there be a team of ‘restricted access’ assessors? Will assessors be available outside of business hours for participants who work full-time or have other contradicting commitments?

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“It is unclear to what extent the needs “I’m worried the ‘reasonable and assessment will adopt the recommendations of necessary supports budget’ concept a participant’s allied health professionals. This is informed from the needs makes it harder for a participant to understand assessment. Will that remove how they can appeal this decision or what possibility of relying on other evidence they will need. It is unclear. evidence? Need more clarity about Additionally, they may be told that they don’t this” need to appeal the decision because the funding can be used flexibility. This would also be very unfair.”

Consideration should be given as to whether it is preferrable that needs assessments are performed

by an unknown assessor sourced by the NDIA who does not know the participant and has only

considered their needs within the context of a one-off assessment, or whether it would be more

appropriate to have assessments carried out by those who are familiar with the participant’s

disability/ies, such as the participant’s allied health professional, specialist or GP.

       "This is a huge concern. Especially when needs assessment contracts recommendations of
    participant's current team of health professionals. I feel review rights needs to be made very clear
                             at outset before changes made or introduced at all." 

  Additionally, if needs assessments are not conducted by someone from the participant’s existing

  allied health or specialist network, the NDIA will need to recruit a significantly sized workforce of

needs assessors. This workforce will need to be able to service all NDIS participants, including those

  living in RRR communities.

 Further consideration must also be given as to how these needs assessments will be accessible for

  clients in RRR communities where there are already 'thin markets' and significant wait times to access

 supports. Recruiting a workforce of needs assessors is likely to further limit the number of qualified

  allied health professionals available to provide therapeutic support. If the legislation requires a

  participant to engage in a 'needs assessment' then there must be a sufficient workforce in these
 communities to provide these assessments.20

      20 Final Report, NDIS Review p.198. (Recommendation 15).

   Disability Advocacy NSW  | website: da.org.au  | Email: da@da.org.au  | Phone 1300 365 085       Page 10

If participants are required to travel to attend a needs assessment, the NDIS must also provide

support to ensure a participant is able to participate in the assessment, particularly if amendments to

the NDIS Act will allow the NDIA to impose significant penalties and sanctions on participants who do

not participate in an assessment once requested.

“I have a client with very limited mobility due to physical and psycho-social disabilities. They live in a rural and remote location with minimal access to services and no supports. This type of client would have even greater difficulty trying to understand, navigate and get access. It is unclear whether supports offered [under the proposed changes] would extend to clients in this space.”

Also, under s32L(5) of the Bill, there is a requirement for the assessment to be prepared and provided

to the CEO of the NDIA ‘as soon as practicable’ after the assessment is completed. However, there is

no requirement for the assessment to be provided to the participant raising further concerns about how

it would be possible for participants to identify a needs assessment that is incorrect or inappropriate.

This raises further concerns as to the transparency of funding decisions made based on a needs assessment and how a participant can address an incorrect or inappropriate assessment.

Finally, the Bill does not explain whether the person carrying out the needs assessment would be the decision-maker as to the amount and type of support needed.21 Under the Bill, needs assessments are not reviewable decisions under s99 of the NDIS Act. Therefore, there is no mechanism for a participant to challenge an incorrect or inappropriate needs assessment or prevent an inadequate budget being set as a result of a needs assessment.

Removal of ‘Reasonable and Necessary supports’ and the introduction of categories distinguish what is and isn’t a NDIS support

Central to the promise of the NDIS is the concept that people with disability have a right to access both reasonable and necessary supports over the course of their lifetime. ‘Reasonable and necessary supports’ are not defined in the current NDIS Act, but s34(1) of the Act provides mandatory criteria which must be met for a support to be considered ‘reasonable and necessary’.

The proposed changes include removing the concept of ‘reasonable and necessary supports’, replacing it with the concept of ‘reasonable and necessary funding’ and creating additional requirements that funding can only be spent on a support if:

      21 Final Report, NDIS Review p.88 -89

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it falls under one of several specific categories (s10 (a) of the Bill), and
it is on a list provided by legislated rules which have not yet been created (s10 (b) of the Bill), and
it is not excluded by rules which have not been created yet (s 10(c) of the Bill).

This is a significant change which places additional burden on NDIS participants seeking to access supports.

It also isn’t clear which currently funded disability supports would (or could) fit into the specific categories of supports under s10(a) that will determine whether a support is a ‘NDIS supports.’ The proposed categories are umbrella terms which we think participants will find difficult to understand and complex to navigate.

Although the proposed s10(a) draws on selected elements of the United Nations Conventions on the Rights of Persons with Disabilities (‘CRPD’), it leaves out other elements of the CRPD such as the right to work and employment. S10(a) does not appear to include supports that would specifically facilitate a participant’s economic participation (which are covered under the current legislation) but does specifically include ‘rehabilitation supports’ and ‘sickness benefits,’ which are not currently funded.

There is also no information or guidance as to what supports are likely to be ‘ruled in’ or ‘ruled out’ under s10(b) and (c). It seems this will largely depend on the outcome of agreements between the Commonwealth and states, which have not occurred yet. This will likely impact many participants if specific supports that are currently funded within an individualised plan are ruled out without an alternative service system in place to fund the support. Because a wider network of foundational and state funded disability supports have not yet been developed, there is significant uncertainty as to what supports would continue to be funded under the NDIS if the changes went through. The types of supports listed in the Explanatory Memorandum (holidays, groceries, payment of utility bills, online gambling, perfume, cosmetics, standard household appliances and whitegoods) are not helpful in identifying the extent of the supports that would be excluded. These supports are already excluded under the current NDIS Act to the extent they represent ‘day to day’ living costs.

choice and control.’23 We disagree. There is nothing transparent or ‘whole of person’ about an

approach whereby assessors perform ‘part of person assessments’ which are then used to assign

group or class of participants. There is nothing transparent or fair about pushing legislative changes which would see participants:

struggle more than ever to make a multitude of fully informed decisions (whilst navigating

new, vague, conceptual language, thin (or non-existent) markets and various other

complicating factors in relation to ‘whole of budget’ funding that they must ‘make work’ to

meet their disability support needs, and
having to ‘choose’ to limit or go without needed disability supports simply because the

allocated funding budget doesn’t accurately reflect their individual need and circumstance.

For many participants, receiving a budget amount which must be spent with reference to generalised

lists of appropriate supports is an arrangement that would likely limit choice and control and create

additional layers of complexity participants must navigate before they can access a support.

“I need someone to come and help me vacuum my floors “The system is already hard

does this support fit into one of the new categories? for people to understand and Why can’t they just provide a list of ‘real world’ supports get evidence for. I think degree in NDIS to be able to understand this Scheme.“ will increase substantially during the transition.”

These changes are likely to result in reduced flexibility in the scheme and significant confusion and

stress for NDIS participants as to how their funding budget can be used. The changes will

simultaneously place the burden on the participant (rather than the planner) to correctly identify

whether a support is an ‘NDIS support’ under s10. A participant who is unable to navigate the

legislation faces significant risk and hardship if they make an error. Under the proposed s46(1) of the

Bill, a participant spends funding on a support that doesn’t meet the new definition of a NDIS support, the NDIA may suspend a participant’s funding. Additionally, under the proposed s182(3) the participant may incur a debt for using funding on supports that don’t meet this definition.

      23 NDIS Amendment (Getting the NDIS Back on Track No. 1) Bill 2024 – Second Reading Speech, Hon Bill Shorten MP, March 2024.

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Information gathering powers and impact on participants

DA is concerned about the introduction of new powers into the NDIS that seem to be particularly punitive and coercive including the power to suspend a plan where a participant does not provide information (s32H, s41 of the Bill) and the power to revoke access to the NDIS (s30, s30A of the Bill).

DA is concerned that these powers would adversely and disproportionately impact the following cohorts:

Participants with multiple and complex disabilities.
Participants with literacy issues and/or cognitive impairments
Participants in RRR areas who face additional barriers to engaging with the NDIA.

For example, under the proposed Bill, if a report is requested, a plan can be suspended if the report is not provided within 28 days. This is concerning because if a participant is unable to obtain a report within this timeframe or is unable to participate in an assessment, for example due to hospitalisation, than they risk losing access to their funding. Additionally, if a needs assessment is not done before a plan reassessment, a participant’s plan can be suspended. How will the NDIA ensure that participants can access a needs assessment in this timeframe and not lose access to their funding?

It is unclear how the NDIA will ensure participants (particularly in RRR areas) receive notifications requesting information within a specified timeframe. Requests must be communicated in a way that is timely, accessible and gives the participant sufficient time to respond where there is a risk that funding will be taken away. Many participants in RRR areas have inconsistent or non-existent access to electronic communication. It would be incredibly unfair if participants were subjected to suspensions of their funding for failing to respond to requests which they were unaware of. It would also be very disruptive for both participants and providers alike if plans were to be suspended without the participant’s knowledge, because the participant could run up a debt with their support providers without knowing. This is because it is only when providers claim for support that they find out whether funding can still be accessed. This can occur weeks or even months after the support has been provided.

These concerns are reflected in feedback we have received from DA disability advocates:

“This will adversely affect participants with “These changes are worrying based on psychosocial disabilities, poor literacy, who the NDIA’s current poor record with use alternative communication means and communicating with clients. It would be good if this was brought in, if there was also participants and carers who are stressed some safety clause, something that and/or overwhelmed. The punitive nature of required a referral to an advocacy service this function will unfairly impact this group. as for example, before they are cut.” it already does through other processes such as social housing.”