The Housing Connection
Together. Yourchoices. Yourdreams
31 Albert Ave
Chatswood NSW 2067
5 September 2019 Ph: (02) 9415 2311 Fax: (02) 9413-4770
ABN: 77 144 980 898
Joint Standing Committee on the National Disability Insurance Scheme thc@thc.org.auSubmission via website www.thc.org.au
Dear Committee Members,
NDIS Supported Independent Living (SIL)
I am writing on behalf of The Housing Connection (THC). THC has been operating since 1981 and currently delivers core services to 173 people and supported independent living services (SIL) to 11 people across the Northern Sydney District. THC has approximately 20 referrals for people seeking a place to live who would require SIL support.
THC has also completed a submission around NDIS planning. The feedback below is under the headings from the reference items identified on the website. The content below is based on our experience of the SIL quoting and approval process, and attendance at planning meetings for SIL participants. Along with feedback from family members/plan nominees.
- The approval process for access to SIL The SIL approval process until 30 June was completed by a SIL planner based in the local NDIA office. Since 1 July, this has been moved to a centralised team, and we recently found out, that providers are now required to submit a SIL quote 8 weeks ahead of the plan review date.
There are constantly changing procedures, around SIL quoting and approval.
The SIL approval process has and continues, to sit as a separate function to the planning process. THC has submitted a submission around NDIS planning. In that submission, under 1, 1.1 & 1.2, some examples were included of lost in translation planning outcomes. The same applies to SIL.
SIL approval should be an integrated function of the planning meeting and not a separate process. Participants requiring/eligible for SIL are mostly people with complex needs, or who require overnight support. It has been our experience that the SIL quote, separated from the planning process, is subjected to extensive negotiation and reduction in the true cost of service delivery to meet reasonable and necessary needs for SIL participants. Hence, there is not a good understanding of the person, the support needs and the context. It just appears to be about driving down the cost.
Scott’s story I hope will illustrate some of the challenges and issues. Scott requires 1:1 support. Scott has a profound intellectual disability with a non-organic degenerative diagnosis. There is clear clinical evidence that identifies his support needs and environmental living requirements. None of this has been adequately considered in the SIL or planning process for the last three years. Scott has been underfunded to meet his needs for the last three years. His third plan has funding for two staff to three clients for only some parts of the day. Scott requires 1:1 support.
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Scott has just had his fourth plan review completed in early August. To date, the planning process has assumed gains in functioning and cognition that is not in line with the evidence from psychiatrists, clinical psychologists, occupational therapists or speech therapists that have been engaged to provide guidance around care.
Scott has lived with one other person for the last twenty years. The NDIA insisted at the beginning of the second plan that because Scott lives in a house with five bedrooms, that there needs to be four other people living with him. This is despite the model of support being historically based on meeting the needs of two people with complex needs and the house is not appropriate to accommodate four people with high support needs. Nor does it operate as traditional group home, as a congregated care option. Nor does this line up with the clinical evidence and advice.
THC has been open to and looking for a possible third person to share this home. There was someone in need of this model of support, who has moved in, and has been living there for the last 14 months. The three participants are not compatible and there is an escalation of challenging behaviours amongst all three people. We are now looking to move at least one person out into suitable other accommodation. If an alternative option can be found! There is a dearth of appropriate housing solutions.
Scott and his now two housemates continue to not have adequate funding in their plans. For example, for the level of staffing required, the skill set of staff required and the level of staff training required. Then there is the ongoing training and support required for example; training in understanding and implementing a behaviour support plan, staff attendance at a monthly practice clinic to review how the behaviour support plans are working and to provide updated training and review of strategies, having a regular team meeting.
For Scott and his home, there is a minimum of eight double up buddy shifts (or 60 hours) for a new staff member to ensure a minimum level of understanding of the participants needs, how the household runs, their routines and the behaviour support training. The cost of this is not covered in the SIL quote. Nor is the level of oversight and service coordination to ensure safety, supervision, staff support and service coordination. This is a vulnerable group of people who rely on their staffing team to do this and their family members are not in a position to do this.
Scott’s year one NDIA plan was less than what he received under ADHC. His needs are still not acknowledged and he continues to not be appropriately funded.
It is not acceptable that the NDIA does not recognise or fund the appropriate resourcing to ensure adequate staffing, participant, staff and community safety.
His fourth plan review took place in early August. There is no feedback yet on the SIL quote submitted. And he has no funded support for two days a week. His family have lodged a plan review over 14 days ago, with no response.
NDIA planners assume that Scott that he will ‘get better’. If this an insurance model it goes against his history and medical advice. Scott’s family are extremely stressed about the planning anomalies. For the last four years, his plan does not line up with evidence from specialists; there is ongoing inadequate resourcing to meet his need across both SIL and his community funded options; along with a lack of consideration of his environmental needs. This is a breach of his human rights.
As a result of Scott having funding allocated at a group rate for his day program, he is administered high levels of PRN medication. And all because he does not have the support he needs.
THC is extremely concerned about the practice requirements from the NDIS Quality and Safeguards Commission, and in particular, those around the reduction of the use of approved restricted practices, that do not line up with the planning process and resources allocation. Scott’s situation highlights this.
Scott is at higher risk in a home with two others, because of his high support needs and lack of appropriate funding. THC has self-funded additional care to ensure the safety of Scott and his co residents. THC is not sure how much longer we can continue to do this, without appropriate planning and SIL resources in place. We are now into year four of plans and none of the issues is resolved.
As an organisation, if we cannot see operational changes, and after three and a half years, the risks may out way the benefits of continuing to deliver services.
At the current time, we have another four people waiting to hear about SIL plan approvals, dating back to July 2019.
We have another SIL participant who requires 1:1 support, but whose SIL approval has been given for five hours Monday to Friday day and six hours for Saturday and Sunday. We are looking to exit this participant as cannot meet her needs with the approved funding. Again all the evidence has been provided to support the level of support she needs.
- Vacancy management process, including its management and costs THC would support having a centralised vacancy management register for the posting of all vacancies by postcode or location. I have seen emails from organisation’s advertising new SDA options. For those I happen to be on their mailing list. There may be others that I am not aware of.
There are a number of websites that also post vacancies for new SDA dwellings, and some SDA matching sites for those who have a home and those looking for a place to live. But there is nothing for existing vacancies. A centralised option would be fabulous.
THC has some people who would benefit from a reconfiguration of their living situation but to date we have not been able to gain access to comprehensive information about vacancies and options. This is such a difficult area given compatibility needs to be a high priority, and has been poorly managed by ADHC previously. The example of Scott above, with NDIA mandating the number of people he should live with is another example of continuing poor practice, with poor outcomes.
To date, THC has not had any vacancies and has no issues around vacancy management. There are more people seeking homes than we have yet to accommodate/find homes for.
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The funding of SIL Most of the issues have been covered of above.
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Any related issues THC operates in an area of Sydney, that has been identified by local providers, and personnel from the DSS - boosting the Local Care Workforce program – as operating in a thin market for staff.
Strategies to support affordable housing to encourage workers to live and work in their local area are required. Along with a loading that recognises thin markets. Such as in place for the Specialist Disability Accommodation (SDA) modelling, or those for regional and remote areas (and not suggesting the issues are the same in this urban location to those in these areas). But a way of recognising geographical variances.
Specialist Disability Accommodation (SDA) requires urgent clarification around eligibility. Social and Community housing providers are refusing eligibility. For example, a person with intellectual disability who requires support to maintain their tenancy and who may have medical issues requires SDA. SDA pathway appears closed to this cohort. NDIA has a convoluted process to access eligibility. In the meantime, there is a whole cohort of people who have no housing solutions available to them.
If you require additional information or clarification, please do not hesitate to notify me.
Yours sincerely,