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Supported Independent Living: what does good look like?
Submission to the Department of Health, Disability and Ageing — August 2026 consultation paper
Prepared by DEC Housing • September 2026
DEC Housing welcomes the opportunity to provide feedback on the Australian Government’s exploration of a possible commissioning approach for part of the Supported Independent Living (SIL) market.
As a Specialist Disability Accommodation (SDA) provider working alongside SIL providers, participants and other stakeholders, DEC Housing sees firsthand the relationship between suitable housing, support quality, participant choice, provider sustainability and successful long-term tenancies.
DEC Housing supports measures that improve the quality and safety of SIL. However, any commissioning model should be carefully targeted and should not inadvertently reduce participant choice, restrict innovation, narrow the provider market or create arrangements in which participants effectively become tied to a particular SIL provider.
We consider commissioning most appropriate where there is demonstrated market failure, heightened participant vulnerability, complex service delivery or limited provider availability. We do not support a single commissioning model being applied uniformly across the SIL market.
DEC Housing also considers that SIL commissioning cannot be examined in isolation from the operation of the SDA market. In our experience, some participants who entered the Scheme through legacy arrangements and retain only a small placeholder or nominal amount for SDA in their plan remain in older group-home accommodation without receiving clear, proactive information about newer SDA options. At the same time, the SDA market has developed unevenly, with oversupply in some locations and design categories and unmet demand in others. Better market stewardship, participant information and coordination between SIL and SDA are therefore essential.
A central principle should be the appropriate separation of housing and support. Participants should be able to change their SIL provider without losing their home. This separation is itself an important safeguard and helps preserve genuine choice and control.
DEC Housing welcomes the opportunity to provide feedback on the proposed commissioning approach for Supported Independent Living.
As an SDA provider working across a range of markets, including metropolitan and regional locations, we see firsthand the interrelationship between appropriate housing, SIL supports, participant choice, provider sustainability and successful long-term tenancies.
DEC Housing supports initiatives that improve the quality and safety of SIL. However, any commissioning model should be carefully targeted and should not inadvertently reduce participant choice, restrict innovation, limit the number of providers in the market or create arrangements in which participants effectively become tied to a particular SIL provider.
We believe commissioning could provide significant benefits in parts of the market where there are demonstrated problems with quality, provider availability, market failure or participant vulnerability. However, a single commissioning model should not be applied uniformly across the SIL market.
Importantly, housing and support should remain appropriately separated. Participants should not lose their home simply because they wish to change their SIL provider.
Which SIL participants could benefit most from additional government oversight of planning, delivering and monitoring of SIL supports?
DEC Housing believes commissioning should be targeted rather than universal.
The participants who may benefit most from additional oversight include:
However, commissioning should not automatically apply simply because a person receives SIL.
Many participants are capable of selecting providers, changing providers and managing their support arrangements with assistance from families, advocates, Support Coordinators or other representatives.
A risk of universal commissioning is that government oversight could evolve into government selection of providers. This could unintentionally reduce the fundamental NDIS principles of choice and control.
We therefore recommend a risk-based commissioning framework, concentrating intervention where there is evidence of market failure, participant vulnerability or unusually complex service delivery.
What do high-quality SIL supports look like?
High-quality SIL should be measured primarily by participant outcomes rather than hours of support delivered.
Good SIL should enable a participant to live an ordinary life in their own home, rather than making the home feel like a workplace or institutional environment.
High-quality SIL should include:
In shared SIL, it is particularly important that shared support funding does not translate into shared lives.
Participants should retain individual routines, preferences and goals even though some staffing may be shared.
Commissioning should therefore establish minimum expectations around outcomes and quality but should avoid overly prescriptive service models.
Government should define what good outcomes look like, while allowing capable providers flexibility in determining how those outcomes are achieved.
How should SIL supports protect the safety, health, wellbeing and rights of participants?
Effective safeguards should protect participants while still respecting their autonomy.
DEC Housing considers one of the most important safeguards to be genuine separation between housing and support.
Participants should be able to change their SIL provider without being required to leave their home.
Where the SIL provider controls both the support relationship and access to the accommodation, participants may feel unable to complain or change provider because they fear losing their home.
Commissioning should reinforce safeguards including:
Government should also pay particular attention to closed-service environments where the same organisation controls housing, support, transport, activities and other aspects of a participant’s life.
Independence between accommodation and support providers provides an additional safeguard because more than one organisation has visibility of the participant’s wellbeing.
How can innovation by SIL providers enhance the quality of SIL supports and outcomes for SIL participants?
Commissioning should encourage innovation rather than inadvertently standardising SIL into one service model.
Innovation could include greater use of:
A major opportunity is better coordination between SIL and SDA.
High-quality accessible housing can reduce some support requirements and improve independence.
For example, appropriate home design, automation and assistive technology may enable a participant to undertake activities independently that would otherwise require direct staff assistance.
The consultation specifically asks how SIL can work alongside other home and living supports, including SDA, hospital discharge and avoiding inappropriate admission to residential aged care. We believe there should be stronger coordination between housing availability and support commissioning.
At present, situations can arise where suitable SDA is vacant while participants remain in hospitals, aged care or inappropriate accommodation because the housing, support and discharge systems are not sufficiently connected.
Commissioning could potentially assist with this coordination without requiring the SIL provider and SDA provider to be the same organisation.
How can effective participant choice and control be enhanced, including in regions with smaller populations?
Participant choice and control must remain central to any commissioning model.
Participants should have meaningful choice regarding:
We would be concerned about commissioning arrangements that effectively allocate a participant to a particular provider with limited ability to change.
This risk is particularly important where a commissioned provider becomes the dominant or exclusive provider in a geographic area.
In regional and thin markets, government may need to take a more active role in ensuring services are available. However, creating a regional monopoly is not the answer to a thin market.
Government should instead consider mechanisms that encourage multiple capable providers to enter and remain in regional markets.
DEC Housing is particularly concerned about participants who entered the NDIS through legacy SDA arrangements. NDIA reporting acknowledges a cohort with a small placeholder amount of SDA funding in their plans until they locate an enrolled dwelling. In DEC Housing’s experience, some of these participants remain in older, institutional-style or run-down group homes and are not always proactively informed about the range of newer SDA dwellings now available.
Choice and control is not meaningful if a participant does not know that alternatives exist. Participants with legacy or placeholder SDA arrangements should receive proactive, accessible information about contemporary SDA vacancies, their assessed eligibility, the steps required to move, and independent support to explore alternatives. The onus should not rest on the participant or their family to discover that a better housing option may be available.
Participant matching is also important.
A vacant bedroom should not simply be treated as capacity that needs filling.
Successful shared living depends on compatibility between participants, including lifestyle, age, interests, communication, behavioural considerations and personal preferences.
Participants should have a genuine say about potential housemates.
Commissioning should therefore measure successful placement based on sustainable tenancies and participant outcomes, rather than simply occupancy.
What is needed to ensure that SIL providers are sustainable?
Provider sustainability is essential to participant safety and continuity of support.
Government cannot reasonably require providers to deliver high-quality, highly regulated services while funding arrangements fail to recognise the actual costs and risks associated with delivering those services.
Providers need sufficient funding to recruit, train and retain skilled workers, particularly in regional areas and for participants with complex needs.
Vacancies in shared SIL arrangements can have significant financial consequences. Providers may retain staffing obligations even when one position within a shared home becomes vacant. A commissioning model should establish a sensible approach to temporary vacancies rather than encouraging providers to place unsuitable participants into homes simply to maintain financial viability.
Funding arrangements should allow enough time to achieve appropriate matching. Pressure to immediately fill vacancies can lead to poor matching, tenancy breakdown and ultimately greater cost to the NDIS.
Prices should reflect genuine service-delivery costs, including:
Additional mechanisms may be required to sustain services in regional and remote areas where normal market economics cannot support multiple providers. These could include regional loadings, availability payments or other targeted mechanisms.
Commissioning should not simply add another layer of reporting on top of existing NDIS registration, Practice Standards, Quality and Safeguards Commission requirements and funding administration. Where additional reporting is required, it should replace or consolidate existing reporting wherever possible.
DEC Housing supports exploring commissioning where it can address genuine market failure or improve participant safeguards.
However, we recommend that any future commissioning model be based on the following principles:
The consultation presents an important opportunity to strengthen the relationship between SIL commissioning and SDA housing.
The consultation paper explicitly identifies SDA as one of the home and living supports that SIL should work alongside. In DEC Housing’s view, this creates an important opportunity to ensure that any future SIL commissioning model recognises the practical realities of housing availability, vacancy management, participant matching and the separation of housing and support.
A well-designed commissioning approach could improve coordination between SIL, SDA, health and discharge systems while preserving the participant’s right to choose where they live and who provides their support.
In DEC Housing’s view, SDA market stewardship has not been sufficiently granular or responsive to local supply and demand. The result is an uneven market: some locations and design categories have substantial vacancies and oversupply, while other areas continue to have limited suitable supply and strong unmet demand. This creates avoidable vacancy risk for providers and, more importantly, can leave participants without appropriate housing in the places they need to live.
The NDIA now publishes SDA demand data by geographic area and regular market reports. DEC Housing considers that these data should be used more actively to guide market development, flag emerging oversupply and undersupply, inform participants and providers, and coordinate planning across SDA, SIL, hospital discharge and mainstream housing systems. Market stewardship should focus not simply on the national number of enrolled dwellings, but on the right dwelling type, design category and location relative to actual participant need.
DEC Housing is a not-for-profit housing provider. This allows us to prioritise participant outcomes, long-term tenancy sustainability and effective use of housing stock rather than seeking to maximise SDA revenue from every bedroom. Where it is appropriate and consistent with participant choice, compatibility and tenancy rights, DEC Housing can support households that include a mix of SDA-eligible participants and non-SDA residents, including NDIS participants who are not SDA eligible.
The NDIS SDA pricing arrangements recognise shared living arrangements in which SDA-eligible participants live with people who are not SDA eligible. For DEC Housing, this flexibility is particularly important in areas where there is excess SDA capacity or where a participant would benefit from living with compatible non-SDA housemates. Any mixed model must preserve informed choice, appropriate safeguards, individual tenancy rights and the separation of housing from support.
DEC Housing would welcome further consultation on the detailed design of any future commissioning model.
Australian Government Department of Health, Disability and Ageing, Supported Independent Living (SIL): What does good look like? Public consultation to help inform a possible commissioning approach for part of the SIL market, Consultation Paper, August 2026.
National Disability Insurance Agency, NDIS Quarterly Report to Disability Ministers, March 2026, Table 11 and accompanying notes on participants with small placeholder amounts of SDA funding.
National Disability Insurance Agency, Specialist Disability Accommodation (SDA) Demand Data, current September 2026.
National Disability Insurance Agency, NDIS Pricing Arrangements for Specialist Disability Accommodation 2026–27, including Appendix H – Shared living arrangements.
