DEC newsA new direction for NDIS participants and disability housing, but will it be right?

Dec 15, 2023

The NDIS Review's Final Report has the potential to be a transformative moment in the landscape of disability accommodation in Australia. The Report lays the groundwork for significant changes in Specialist Disability Accommodation (SDA) and broader housing options, directly impacting participants of the National Disability Insurance Scheme (NDIS).

The current state of the disability accommodation sector

The Report reveals pressing challenges within the current disability housing sector. A notable proportion of SDA participants continue to live in group homes or legacy stock, highlighting a stark lack of innovation and limited housing choices and living supports for people with disability. For many participants, especially those transitioning to what to the euphemistically described 'legacy stock' (I'm not sure anyone would really want this housing as their 'legacy'!), the options for contemporary and accessible housing are limited.   These options are not enhanced by the reality faced by people with disability who were living in group homes when the NDIS was introduced and who, in DEC Housing's recent experience, have been funded to the level of 'SDA-Basic' before going through the bureaucratic maelstrom that is a Housing and Living Option (HALO) application/review.    

Barriers to Progress

The Report describes a sector in which providers are grappling with challenges such as limited access to best practice information and ongoing reforms, hindering their ability to improve service models. The NDIS's individualised pricing structure has been problematic, especially in shared living setups, leading to funding unpredictability and high staff turnover.

A desired future state for disability accommodation

The Review Panel's vision introduces a future where NDIS participants can choose from diverse housing and living options tailored to their specific needs and circumstances. This, of course, aligns with the NDIS's core mission of enhancing choice and control for people with disability and speaks to the Review Panel's commitment to ensure the NDIS ‘delivers on its promise' (a phrase that will be familiar to anyone who's been working in the sector over the past ten years or so).

Recommendation 9: Impact on Participants

Recommendation 9, which focuses on delivering a variety of inclusive housing and living supports, may suggest a shift towards more participant-centred solutions. Implementing these recommendations will, however, involve legislative changes and a new approach to funding, focusing on service quality and outcomes for NDIS participants. It will also require, as one would expect, a great deal more detail to flesh out what is being recommended and how it will be delivered, in what circumstances and with the support of which level(s) of government.    

There are 11 Actions under Recommendation 9, some more radical than others, and each could probably justify an article in its own right. Where I have thought the recommendation warrants a comment, I have included one.

Action 9.1: The National Disability Insurance Agency (NDIA) should collaborate with the new National Commission to gather and share detailed data on housing and living supports. A robust evidence base should be developed to inform diversity and innovation in housing and living supports and guide effective market stewardship.

Action 9.2: Implement a new funding approach for participants sharing living supports, focusing on service quality and outcomes. Design this approach with input from participants, families, and the sector, outlining a set of shared supports to be provided by living support providers. Pool participants' funding for these shared supports and align reviews for participants sharing supports.

Comment: This looks like the 'SDA for those without SDA but prepared to share their supports' recommendation! We must confirm criteria and eligibility, funding levels, and resident numbers in any single home/abode, amongst other issues.    

Action 9.3: The NDIA should release detailed and frequent information on participant demand for 24/7 living supports and SDA, including current vacancies and features of SDA dwellings. Data should be published quarterly to ensure the SDA market can build the right types of abodes in suitable locations.

Comment: If possible, this data needs to include updates on the number of homes being built in a region at any point in time. It's one thing to say that 'demand for SDA housing is x', but if supply is 'x +1', then it's important for SDA providers to know this to support better business decision-making.    

Action 9.4: The NDIA should remove the Improved Liveability category for new SDA developments and review the remaining SDA categories and Design Standards. The review should assess if the existing categories meet participants' needs and suggest alignment with the National Construction Code.

Comment: This recommendation is not unexpected, but it has implications for all governments with ambitions to build and support new public, social and affordable housing stock. New build projects and funding must take account of demand from people with disability and their needs, and this includes people with disability wishing to leave hospital and therefore requiring high-quality medium-term accommodation, which is still reasonably close to the hospital they have left. 

Action 9.5: Transition responsibility for advising on SDA pricing to the Independent Health and Aged Care Pricing Authority. Introduce flexibility in pricing, allowing for exceptions in certain circumstances.

Comment: A call the sector and its peak bodies have been making for years and one which may be bitterly opposed by the NDIA and its Board (as has been the case in the past). It's a simple argument: the Agency has a conflict in continuing to set prices while providing funding for supports.

Action 9.6: In consultation with state and territory governments, the NDIA should commission SDA where private investment is insufficient. Focus on remote locations and participants with specialist or complex needs.

Comment: this is a potentially massive departure for the Agency, given that, even before the Agency was established, its designers and supporters were declaring it 'will not be in the business of bricks and mortar' and other colourful phrases. This recommendation explicitly recognises that the SDA market needs government intervention to work as intended for all Australians with disability. 

Action 9.7: Strengthen SDA regulation through the new National Disability Supports Quality and Safeguards Commission. Enforce compliance with SDA practice standards and mandate separation of SDA and living support providers.

Action 9.8: Develop an intergovernmental strategy for upgrading or repurposing ageing SDA stock owned by states and territories. The strategy should include timelines and collaboration with residents and advocates.

Comment: Without wishing to pre-empt the strategy's development, its focus should be less on 'repurposing' and more on 'demolishing, replacing and divesting' given the current, well-documented condition of much of the housing stock still owned by state and territory governments. 

Action 9.9: Amend NDIA policies to reduce the bedroom count of ageing SDA dwellings when participants exit, allowing re-enrolment at a lower resident count. 

Action 9.10: Introduce a new SDA category for participants funded for shared living supports but ineligible for existing SDA categories. Design the new category with sector input, focusing on cost-effective supports for shared living.

Action 9.11: All Australian governments should agree and publish a targeted action plan for housing under Australia's Disability Strategy.

The plan should focus on improving social housing suitability for people with disability, including adopting Liveable Housing Design Guidelines.

Implications for NDIS Participants

If implemented, the recommendations contained in Part 9 of the Report are intended to provide participants with more autonomy and options in selecting housing that best suits their needs. 

The proposed separation of SDA and SIL services is also intended to ensure greater transparency and reduce conflicts of interest, leading to improved service quality. This change is pivotal for participants seeking more personalised and effective living arrangements.

Broader Reforms in the Sector

The Report also highlights the need for wider reforms in the disability sector. These include a stronger focus on safe and effective support for participants requiring 24/7 care and support and a collaborative effort across governments to upgrade and repurpose ageing SDA stock.

A pathway towards a better housing future for people with disability

The NDIS Review's Final Report outlines a pathway towards a more inclusive, innovative, and participant-focused approach in disability housing. For NDIS participants, this represents a significant step towards potentially greater empowerment and choice in their living arrangements. The recommended changes, if accepted and implemented by the Federal Government, are intended to align services more closely with participants' individual needs and preferences.

But will they herald a new era in disability accommodation in Australia? Or will we be back again in 10 years arguing for 'more radical reform this time'? We have to grasp the nettle now and support reforms to accessible housing for people with disability that will make a difference… now!

David Moody General Manager, Operations, DEC Housing

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