Joint Standing Committee on the National Disability
Insurance Scheme: Supported Independent Living
Whatever words we choose to use when we talk about housing and support for people with significant disability it should be home we have in mind.
Home is a rich and evocative word. It’s where you reside, but it’s more than that. Home is where you can express yourself, remove your armour, relax, feel safe, entertain friends, be accepted for who you are. In our collective imagination home is a haven from the outside world. Home is cosy and familiar; it’s where you have a sense of dominion.
A key aim of Supported Independent Living (SIL) providers should be to help create or maintain a sense of home. This is consistent with the objects and principles of the NDIS. For people with significant disability, this includes being well supported to live where and with whom you want.
As a signatory to the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD)1, Australia is committed to enhancing the opportunities for people with disability to “participate in all aspects of social and political life including access to employment, education, health care, information, justice, public transport and the built environment.”2 One of the six priorities of the National Disability Strategy—endorsed by COAG in 2010 and designed to help Australia meet its obligations under the UNCRDP—is ‘economic security’. Under this priority, the Strategy notes:
A secure and affordable place to live is the basis of economic and social participation in the community. For many people with disability there are additional dimensions around the capacity to visit friends and family and to choose where and with whom they wish to live. People with disability require a range of housing options, including public and social rental, and private rental and purchase.3
A priority policy action is to “improve access to housing options that are affordable and provide security of tenure”. Providing the support for some people with disability is critical to creating a home.
SIL is instrumental in people with significant disability creating their home. While it is working for some NDIS participants, this experience is not universal. Comments in this submission reflect the experiences of SIL providers and are provided to assist with identifying where improvements can be made.
1 http://www.un.org/disabilities/documents/convention/convoptprot-e.pdf 2 COAG 2011, ‘2010–2020 National Disability Strategy’, FaHCSIA, Canberra, p.53. 3 Ibid. p.53.
NDS survey of SIL providers
NDS is continuing to hear of growing SIL vacancies. To inform this submission, NDS asked its members to answer a short survey.
Responses were received from 124 organisations. These organisations reported they supported a total of 9,794 SIL places, with 909 current vacancies. This vacancy rate of just over 9 percent reflects issues which need to be understood and addressed.
Respondents were asked to report on the average length of vacancies as well as their longest vacancy. The median average vacancy was 24 weeks, with a mean of 25 weeks (nearly six months). Eighteen respondents reported an average of over 52 weeks, with the longest average vacancy reported as 84 weeks.
In terms of the longest reported vacancy, the median was 40 weeks, the mean was 48 weeks, and the maximum was 156 weeks. Twelve respondents reported a longest vacancy of 104 weeks or longer.
Respondents were asked to describe the biggest barriers to filling vacancies. There were 120 responses in total.
A thematic analysis was conducted of these responses to identify the main categories of responses. As respondents were free to leave as long or short a comment as they liked, many responses fell into multiple categories (and there is overlap). There were three main categories: NDIS Process and Administrative Burden (86 comments) – Comments citing burdensome or unclear processes, and the slow decision making. Participant Matching and Transition Process (75 comments) – Comments that mentioned difficulty in matching prospective participants to current participants, or meeting participant needs. Additionally, comments mentioned difficulties in advertising vacancies, finding prospective participants, and difficulties in coordinating SIL with other supports, and organising participant transition. Residence Related Issues (15 comments) – Issues related to either the availability of housing, or difficulties arising from housing location (e.g. remoteness), or fit-out.
In terms of specific barriers within these categories, the top 5 most mentioned were:
-
Participant compatibility (44 comments) – comments related to difficulty finding new participants compatible with current participants.
-
Timeliness of reviews/approvals (42 comments) – comments mentioning the length of time needed to obtain SIL quote approvals, (or SDA and SIL approvals), having funding put in plans, or reviews of participant plans.
-
The SIL assessment process (30 comments) – Comments specifically mentioning the process for getting SIL approved and funded as burdensome, unclear or too long.
-
NDIS Processes (26 comments) – Comments referring to general difficulties in navigating NDIS processes.
-
NDIS Plans – Comments related to the difficulties in getting SIL or SDA into participant plans (24 comments).
While the majority of these barriers relate to funding or approval processes for SIL, the ability to find new participants to fill vacancies who are a good match with current participants was also a major concern for many respondents.
The approval process for access to SIL
All providers of SIL needing to fill a vacancy complain of lengthy delays. Even when they have a participant keen to move in, delays in the approval process can run to months.
If the SIL vacancy is not in an SDA property, a provider will need to find a potentially compatible person (that other participants are willing to have move in). Evidence of their supports needs will need to be collected and a SIL quote submitted (a participant new to receiving SIL supports will generally need to initiate a plan review). Generally, months will pass before the SIL quote is approved and the participant can move in.
If the SIL is to be provided in an SDA property, the delays can be even greater. Firstly, a prospective new resident needs to be identified (we will assume they are already an NDIS participant). Compatibility with other residents will need to be established, and the views of all participants will need to be considered. Providers need to be mindful that this is someone’s home; participants need to be happy with the prospective living arrangements including co-tenants. This takes time.
The prospective new resident will need to be approved for SDA; if not yet approved, they will need to request a plan review to seek approval.
Once a participant is SDA-approved, they will need to be assessed to determine the level of SDA they are eligible for. The delays in this assessment are lengthy.
If the participant is assessed at a suitable level of SDA, the SIL provider will then need to develop a quote for their SIL supports, gathering evidence for the quote. The approval of the quote can then take months.
All up, it can take many months (and even more than a year) to fill a SIL vacancy in an SDA property (particularly where the participant will be new to SDA and SIL). Streamlining these processes to reduce vacancy periods is urgently needed.
As the vast majority of SIL is provided in shared living arrangements, the impact of a vacancy on other participants living in the property is significant (noting our quick survey indicated more than 900 vacancies cross 124 organisations, so the total number of participants impacted could be 3 to 4 times this number).
SIL funding for shared living arrangements generally comprises some shared supports (calculated on the number of participants sharing the home) plus some individual supports. A vacancy results in less funding being available for the shared supports (which may be for many months), which will mean less support for remaining participants (unless the provider is prepared to carry the cost of maintaining shared supports at the pre-existing level).
The vacancy management process, including its management and costs
As noted above, vacancies often impact on other participants living in shared supported accommodation. They are also very costly for providers.
Unfortunately, there is no ‘quick fix’ for filling vacancies. Greater availability of information about SIL vacancies and those participants seeking SIL will help but it is only part of the equation (noting there are websites emerging to advertise SIL vacancies).
Compatibility of residents in shared supported living must be considered, alongside preferences of all people who will share the home. Shortcuts should not be taken when working with participants on this as it is people’s home.
Where a SIL vacancy is within an SDA, the NDIA must find ways of streamlining the current multi-step process. It is too cumbersome and drawn out.
A related issue is that arrangements for responding to crises in accommodation (either ‘maintaining critical supports’ or providing them to someone who isn’t yet an NDIS participant) are not yet well developed. This needs to be prioritised.
Participants should not be disadvantaged by a vacancy; it is not their responsibility to fill it. The NDIA should ‘top up’ the SIL funding for remaining participants for a period of time to prevent this from happening. A participant may also need temporary accommodation for months while a more permanent arrangement is put in place. Options for this need to be available.
The funding of SIL
SIL is a high cost support, accounting for 32 percent of annualised committed supports in current NDIS plans4 (ranging from 27% in VIC to 49% in NT).
The table below highlights the large variance in the proportion of participants with SIL funding (from 5.9% in the ACT to 11.9% in TAS and 12.8% in NT). Using NDIS data from the latest Quarterly Report (and taking it at face value), it is possible to calculate the average funding per SIL participant. This indicates the average funding per SIL participant varies greatly across the jurisdictions. Excluding NT, WA has the lowest average SIL funding of $256,154, compared with $322,784 in TAS (and $313,119 in QLD and $308,849 in ACT).
The Quarterly Report does not give reasons as to why there is such a large variation in the proportion of participants who receive SIL across the country, and in the average funding they receive. Do these differences reflect historical factors, variability in disability profile across the country, different approaches to developing SIL quotes, differing cost structures of providers, or inconsistent quote approval practices of the NDIA?
4 NDIA, June 2019, COAG Disability Reform Council Quarterly Report, pp. 389-391
Number % with Total committed % committed Ave SIL per
with SIL SIL funds for SIL funds for SIL participant
NSW 7708 7.6 $2,204,289,422 35 $285,974
VIC 4711 6.2 $1,263,211,481 27 $268,141
QLD 3959 8.1 $1,239,636,322 31 $313,119
WA 1062 6.5 $272,035,894 29 $256,154
SA 2131 7.6 $620,958,061 37 $291,393
TAS 777 11.9 $250,803,408 48 $322,784
ACT 412 5.9 $127,245,629 32 $308,849
NT 292 12.8 $144,597,125 49 $495,196
Total 21052 $6,122,777,342 $290,841
Anecdotally, NDS has heard that variable approval practices of NDIS regional offices has led to a recent decision to centralise the approval of SIL quotes.
Given that inequities in the supports provided to people with disability across the states and territories was a driver for implementing a national disability scheme, we need to understand whether these differences are justified or not.
Planning for SIL is often done separately from planning for other supports. The overall funding package should be considered as a whole to ensure there are no gaps or duplications.
Related issues
Payment problems NDS’s submission on NDIS planning makes comments about plan gaps. Gaps in plans for SIL participants become very costly for providers very quickly (particularly as they can occur for all residents of a property at the same time).
NDS notes the NDIA is seeking a remedy for these gaps, however, in our view, it is too early to know whether it has been effective).
September 2019
National Disability Services is the peak industry body for non-government disability services. It represents service providers across Australia in their work to deliver high-quality supports and life opportunities for people with disability. Its Australia wide membership includes over 1050 non-government organisations which support people with all forms of disability. Its members collectively provide the full range of disability services—from accommodation support, respite and therapy to community access and employment. NDS provides information and networking opportunities to its members and policy advice to State, Territory and Federal governments.