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Support Coordination and Connection Reform
Submission to the Department of Health, Disability and Ageing and the National Disability Insurance Agency — September 2026 consultation paper
Prepared by DEC Housing • October 2026
DEC Housing welcomes the opportunity to provide feedback on the NDIS Support Coordination and Connection Reform Consultation Paper.
As a provider of Specialist Disability Accommodation (SDA), we work with support coordinators every week. They are very often the person who first recognises that a participant needs a different home, who pulls together the evidence for a Home and Living decision, who finds the vacancy, and who brings the participant, their family, the SDA provider and the Supported Independent Living (SIL) provider to the same table. In our experience, the quality of that work is the biggest single factor in whether a participant ends up in a home that suits them, and whether that tenancy lasts.
We support the reform’s intent. The Consultation Paper correctly identifies poor and inconsistent service quality, conflicts of interest, and fraudulent practice as problems in parts of the current market [1]. The NDIS Quality and Safeguards Commission, the NDIS Review, and the Disability Royal Commission documented those problems well before now [2][3][4]. The proposal that SCC providers and workers cannot deliver other NDIS supports is overdue, and we support it.
DEC Housing does, however, have real concerns about the preferred lead organisation model and about how SCC providers will be selected.
Our central concern is that commissioning changes who the customer is. Today, a support coordinator has to ensure the participant is satisfied, because the participant can leave. Under a commissioned model, a provider must first satisfy the NDIA’s tender assessors. A tender is written to appeal to the people who assess it. That is not the same thing as being the provider a participant would choose, and an organisation with a well-resourced bid team can produce a very strong tender without being the organisation participants would rate most highly on the ground. If SCC panels or lead organisations are to be established, the assessment process must include measures that test what participants actually experience, not just what providers can write.
In summary, DEC Housing’s position is that:
DEC Housing is a registered SDA provider. Our interest in this reform comes from where support coordination meets housing. For the participants we house, or who are looking for housing, a capable support coordinator can be the difference between a well-matched, stable tenancy and a rushed placement that fails within a year.
In August 2026 we made a submission to the SIL commissioning consultation [5]. Several of the principles we put forward there apply equally here: genuine choice and control; appropriate separation between housing and support; commissioning targeted at demonstrated problems rather than applied across the board; and success measured by participant outcomes rather than service volume. We have tried not to repeat that material, but the two reforms will interact, and they should be designed with each other in mind.
The Consultation Paper invites responses to either or both sets of questions. We have responded to those only where DEC Housing has the most to contribute. Each question is reproduced in italics, followed by our response.
What is working well in support coordination today that you would like to see in the new SCC service?
The best support coordinators we deal with share three attributes:
Specialist support coordination has been particularly valuable for participants with high and complex needs who are moving home. Much of that work is unglamorous: assembling occupational therapy and housing evidence, coordinating site inspections, working through residency agreements and making sure supports are in place on the day of the move. The new service needs to protect this capability rather than lose it in the transition.
What would you most like to see improved in the new SCC service?
From DEC Housing’s perspective, the key improvements are:
What participant groups will benefit most from the SCC service? What do their needs for connection and coordination of supports look like?
Among the participants DEC Housing deals with, the groups who most need a strong SCC or SCC+ service are:
For these participants, connection and coordination is intensive at specific points, such as a move, a discharge or a crisis, and much lighter in between. The service model and payment model need to allow for that pattern.
What experience, skills and knowledge do you look for in an SCC worker?
Alongside the general skills the Consultation Paper describes, DEC Housing would want SCC workers to have a working knowledge of SDA and SIL, the Home and Living process, tenancy rights and the mainstream social and community housing system. SCC+ workers in particular should be able to manage a complex move from start to finish, including the hand-off between the SDA provider, the SIL provider, allied health and, where relevant, the hospital.
What would help you feel safe when receiving SCC services and encourage you to report an issue if needed?
Participants feel safe raising concerns when they know doing so will not cost them their home, their supports, or their worker. In our SIL submission, we argued that the most important safeguard in SIL is genuine separation between housing and support [5]. The equivalent here is a participant’s right to change SCC workers or providers without having to justify the decision, and without any effect on their other supports. Under a single lead organisation model, that right is hard to deliver, which is one reason we have reservations about it.
What commissioning arrangements would best balance participant outcomes, quality, sustainability and choice and control?
DEC Housing’s preference is for a multi-provider panel in each region, with participants able to choose between panel members and to move between them. A panel retains a degree of competition on quality, which is what keeps providers focused on participants. It also reduces the risk of having a single point of failure in a region if a lead organisation underperforms or exits. A single lead organisation model should be reserved for genuinely thin markets, where a panel is not viable.
Whatever model is adopted, the NDIA will have to choose providers through a procurement process. We think this is where the reform carries its greatest risk, and the Consultation Paper does not address it.
An organisation applying to be an SCC provider will write its submission for the people assessing it. It will reflect the language of the tender documents, the NDIA’s stated priorities and the evaluation criteria. That is rational behaviour, and every experienced bidder does it. But the people who will eventually use the service are not the people scoring the tender. Participants do not read tenders, and the qualities that score well on paper (polished frameworks, governance diagrams, policy statements) are not necessarily the qualities participants value (a worker who turns up, knows the local options well and returns calls promptly).
There is also a scale effect. Large organisations with dedicated bid teams will, by definition, usually produce stronger written applications than smaller specialist providers with deep local relationships, regardless of how well each serves participants. Without correction, the process will tend to select for bidding capability rather than service quality.
DEC Housing therefore recommends that the assessment process include the following measures:
Put simply, the test for awarding an SCC contract should be whether participants would choose this provider, not whether the provider wrote the best submission.
What provider types would be best placed to be a lead organisation? Why do these characteristics matter? What are the advantages and disadvantages of the lead organisation model?
We accept that the lead organisation model offers some advantages. It gives the NDIA one point of accountability per region, simplifies contract management and could assure coverage in areas the current market does not serve well.
The disadvantages are significant, however:
If the lead organisation model goes ahead, the lead organisation should have no ownership, partnership, or referral relationship with any SDA, SIL, or other NDIS provider in its region; should have a demonstrated local and physical presence; and should be required to subcontract a meaningful share of work to specialist and community-controlled organisations.
What would be appropriate regional areas to use for SCC service areas?
Housing markets are local. In metropolitan areas, a region the size of a Primary Health Network is too large to support the local housing knowledge SCC workers need. DEC Housing suggests that regions be large enough to sustain a panel of providers, but no larger, and that the NDIA test any proposed boundaries against where participants actually live, where SDA is being built, and where hospital discharge pathways run.
How might SCC providers manage variable need among the participants it supports? Which workforce, caseload, and service capacity factors should be considered?
Caseloads should be weighted for complexity and for life events. A participant moving into SDA, or leaving hospital, may need many hours of coordination in a few weeks and very little for months afterwards. Providers should be required to show how they will provide surge capacity at those points without letting other participants go without.
Which payment and funding approaches would best support participant outcomes, workforce sustainability and innovation?
The Consultation Paper rightly notes that the payment model must avoid incentives that limit access for particular groups or lead to too much or too little support [1]. Pure block funding gives providers every reason to under-service their most demanding participants. DEC Housing would support a blended model: a base payment for capacity, a component linked to activity and complexity, and a component linked to outcomes. For participants needing housing, relevant outcomes would include time from a Home and Living decision to a move, sustained tenancies at twelve months, and reduced delays in hospital discharge.
What quality, workforce and safeguarding requirements should apply to commissioned SCC organisations?
DEC supports the elements listed in the Consultation Paper [1]. The NDIS Review recommended that Navigators be independent of other NDIS services [3], and we agree. On conflicts of interest in particular, the prohibition on SCC providers delivering other NDIS supports should extend to related entities, to shared directors and executives, and to any referral, marketing or financial arrangement with SDA or SIL providers. SCC providers should be required to keep and report records of which SDA and SIL providers their participants are referred to, so that patterns of steering can be identified. All SCC providers should be registered with the NDIS Quality and Safeguards Commission.
How can the future SCC model attract, build and retain workforce capability, including retaining participant relationships?
Where a participant wants to retain their current support coordinator, and that person is willing and appropriately skilled, the system should do everything it can to make that happen. Incoming SCC providers should be required to offer employment to experienced support coordinators in their region, and participants should be able to nominate their existing worker. Funding must also be sufficient to pay and supervise a qualified workforce. A model that squeezes price will lose the most experienced practitioners first.
How should local knowledge and community connection be defined and assessed?
This connects directly to our concerns about tender assessment. Every applicant will claim local knowledge and strong community connections. Assessors should look for verifiable evidence: referral data, current working relationships, references from local housing, health, and community organisations, and the location and tenure of the staff delivering the service. A narrative description of local connections should carry little weight on its own.
How can the SCC service best support participants in regional, rural and remote areas, or other thin markets, where support options may be limited?
In thin markets, SDA is often scarce, and a participant may have to choose between staying close to family and moving to a city for suitable housing. SCC workers in these regions need the knowledge and time to work through those trade-offs properly. Regional loadings, funded travel and partnerships with local community-controlled organisations will be needed. This is where a lead organisation model may be justified, but the safeguards described above should still apply.
How can the SCC service best support participants who face additional barriers, including those experiencing complex and overlapping support needs or requiring decision-making support?
Housing decisions are among the most significant decisions a participant will make. Participants who need decision-making support should have it in place before making a housing decision, and SCC workers should never be in a position where they are effectively making that decision for them. SCC+ should explicitly include coordination of complex housing transitions as one of its functions.
What transition arrangements would minimise disruption and support successful implementation?
On 1 July 2028, some participants will be partway through a move, a Home and Living application, an SDA tenancy start or a hospital discharge. Their current coordinator should be able to complete that work, under transitional funding, rather than hand it over mid-stream. The transition also coincides with broader planning reforms, including the move to New Framework Planning [1]. The NDIA should publish the list of commissioned providers in each region well before commencement so participants, families, SDA providers and SIL providers can prepare. A staged, region-by-region rollout would allow problems to be identified and fixed before they affect every participant.
DEC Housing recommends that:
For participants who need SDA, a good support coordinator is often what turns a funding decision into a home. Commissioning will only improve outcomes if the providers selected are the ones participants would choose, and if those providers continue to answer to participants once the contract is signed. That depends less on the model chosen than on how providers are assessed and held to account, which is where DEC Housing has focused this submission.
DEC Housing would welcome further consultation on the detailed design of the SCC service, the procurement process and the interface between the SCC, SIL and SDA reforms.
[1] Department of Health, Disability and Ageing and National Disability Insurance Agency, NDIS Support Coordination and Connection Reform: Consultation Paper, September 2026.
[2] NDIS Quality and Safeguards Commission, Own Motion Inquiry into Support Coordination, Part 1 report, 2023. https://www.ndiscommission.gov.au/sites/default/files/2023-08/Own%20Motion%20Inquiry%20report%20Part%201%20final.pdf
[3] Independent Review into the National Disability Insurance Scheme, Working together to deliver the NDIS: Final Report, December 2023. https://www.ndisreview.gov.au/resources/reports/working-together-deliver-ndis/
[4] Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, Final Report, Volume 10, Recommendation 10.4: Quality of support coordination. https://www.health.gov.au/resources/publications/disability-royal-commission-progress-report-2025/volume-10-disability-services/recommendation-104-quality-of-support-coordination
[5] DEC Housing, Response to Supported Independent Living (SIL) Commissioning Consultation, 2026. https://dechousing.org.au/response-to-supported-independent-living-sil-commissioning-consultation/
