Joint Standing Committee on the National Disability Insurance Scheme
PO Box 6100
Parliament House
Canberra ACT 2600
Monday 27th February 2017
Attention: Joint Standing Committee on the National Disability Insurance Scheme
The provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition
Homelessness NSW welcomes the opportunity to provide comment into the Joint Standing Committee on the National Disability Insurance Scheme (the Standing Committee) review into the provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition
As you may be aware, Homelessness NSW is a peak not for profit organisation that works with its members to prevent and reduce homelessness across New South Wales. Our members include small, locally based community organisations, multiservice agencies with a regional reach and large State-wide service providers all of which provide services and support to people at risk of or experiencing homelessness.
Homelessness NSW is in the process of organising an NDIS briefing session for Specialist Homelessness Services (SHSs) in New South Wales. Following this meeting, Homelessness NSW will prepare a report into SHS’s experiences with NDIS, which we would be happy to share with the Joint Standing Committee.
In general, Homelessness NSW members have indicated a belief that much more attention has been focused on the big picture of NDIS reform rather than the detail of its implementation. As a result, many people with psychosocial disabilities, particularly those at risk of or experiencing homelessness, are finding it difficult to navigate the complex regulations and application process and many of those found to be ineligible are left with limited support (discussed in detail below).
SHS and NDIS
Members have reported to Homelessness NSW that they are often left in the position of ‘being left to hold the baby’ in terms of managing complex clients who are deemed ineligible to obtain a NDIS package. In our members’ experience, many people with complex needs (including psychosocial disabilities) are being found to be ineligible for a NDIS package. Without access to NDIS, these clients are being referred into an already overstretched SHS sector who are unable to provide the specialist mental health treatment which they require.
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Phone: 02 8354 7605 | Email: admin@homelessnessnsw.org.au | ABN 37 596 554 677
This situation is magnified by the current operation of the ‘no wrong door’ policy within the SHS system in NSW which effectively requires SHSs to provide services to this client cohort without adequate resources. Members have expressed concerns that such ‘client dumping’ with be increased as more disability and mental health services transfer to NDIS and that those not eligible for NDIS will be left to find an appropriate and quality support provider from a diminishing pool of services.
In part, Homelessness NSW believes this problem to be the result of the difficulty clients and their advocates experience in making an application for a NDIS support package (discussed below). However, we also believe that greater coordination between disability, mental health and SHS sector to ensure referrals are made appropriately and with an awareness of the types of support clients require (and the supports the SHS is able to provide).
Homelessness NSW members have also expressed concerned that their clients are receiving inadequate follow up after being granted a NDIS package based on a psychosocial disability. Given the transient nature of homelessness, many people require multiple follow ups to ensure they receive service information. This is even more the case for those experiencing homelessness whom have complex mental health conditions. Members have reported to Homelessness NSW examples when NDIA services have made only limited attempts to contact a successful applicant for a NDIS package. As a result some of the most vulnerable clients have not received the services they have been deemed eligible to receive.
Unclear regulations and criteria
Homelessness NSW believes more work is required to ensure those with a psychosocial disability and their advocates are able to effectively navigate the application process. Members have stressed to Homelessness NSW the complex and confusing nature of the regulations attached to the NDIS support package application process. This has led to many potentially eligible advocates not making or submitting incomplete applications which are ultimately rejected.
One area of confusion for members is the current requirement within the NDIS regulations of the need for an applicant to have a ‘permanency of condition’. Several Homelessness NSW members have expressed concern at the inappropriateness of this requirement given the episodic nature of mental health for many people. We note that in practice an episodic condition does not necessarily disqualify an individual from receiving support through NDIS. However, clearly some advocates (and potentially applicants) do believe episodic conditions are precluded under NDIS.
Members have also highlighted that the language currently used in the regulations can act as a barrier especially to people with a disability from Culturally and Linguistically Diverse (CALD) groups.
Homelessness NSW believes that that Standing Committee should consider recommending reforms to the current regulations to provide more clarity to applicants and their advocates.
Services in regional and remote locations
Homelessness NSW members have also expressed concern about the ability of people experiencing homelessness with a psychosocial disability in regional and remote locations to access NDIS packages. With the limited services on offer in such locations, it is unclear how the NDIS values of user choice and accessibility can be achieved.
We would be pleased to discuss any aspect of our submission. Please contact me on