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Inclusive mainstream services coordinated with the NDIS

All Australians rely on mainstream services such as health, education and transport. There are also a range of programs and activities based in the community such as those run by community groups, non-government organisations, sporting clubs, local councils, employers, church groups and charities.

Ensuring people with disability can use the same services and participate in the same activities as everyone else is a fundamental human right. More inclusive and accessible mainstream and community services will not only produce better outcomes for people with disability but can also reduce the need for more specialist supports over time.

The NDIS should operate within an ecosystem of services that work together to ensure people with disability can access the right mix of supports at the right time in a connected and inclusive way.

Progress to make Australia’s mainstream services inclusive and accessible has been slow

Prior to the roll out of the NDIS, all Australian governments had agreed to make their mainstream services more inclusive and accessible. This was set out in the first National Disability Strategy (NDS), which ran from 2010 to 2020.43 However, progress has been slow, with governments prioritising the rollout of individualised supports under the NDIS. People with disability continue to face barriers accessing the supports they need and participating in their community.

Being able to access mainstream services is a human right under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD).44 Australia meets its UNCRPD obligations through, for example, the NDIS, Australia’s Disability Strategy, 2021-2031 (ADS), the Disability Discrimination Act 1992 (DDA), state and territory disability legislation, disability action plans, standards for accessibility, and policy impact assessments.

In spite of good intentions, Australia’s approach to inclusion, including legislation, has not been strong or comprehensive enough to drive change at an acceptable pace or equally for all groups of people with disability. Complaints under the DDA have more than doubled between 2017-18 and 2021-22.45 We have heard concerns with how fit-for-purpose and contemporary Australia’s approach is to disability rights, discrimination and inclusion legislation, including the current DDA.46

The Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability has also highlighted the need for a stronger and more comprehensive legal framework, including a Disability Rights Act, which would protect and promote the human rights of people with disability and shift the legislative burden away from individuals with disability reporting discrimination.47

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There is a lack of coordination across systems to support people with disability

The introduction of the NDIS and its often complex interface with many mainstream services has made navigating multiple systems more difficult. Many of the issues raised consistently by people with disability stem from the failure of government agencies to agree on shared responsibilities and working arrangements under the current Applied Principles and Tables of Support to Determine Responsibilities of the NDIS and other service systems (APTOS).48

The principles, roles and responsibilities outlined in APTOS have not translated into consistent collaboration on the ground. The underlying structure of APTOS may be part of the problem - it assumes people with disability will be supported by the NDIS or another system. In reality, they need support from both. This leaves people with disability confused about how and where to find and use supports, and in some cases with no access to support at all.

Clear responsibilities and effective coordination between agencies are critical for all people with disability. Mainstream services often have their own eligibility criteria and access requirements, which can be inconsistent and contradictory. In some cases, access to one support can preclude access to another complementary or necessary support, such as access to assistive technology, supports for children with developmental delay, or some supports provided in educational settings.49

Without sufficient planning and integration, people with disability can experience not only complexity and inconvenience, but also negative health outcomes and risks to safety and wellbeing.

…instead of using the entry of the NDIS to encourage much needed, more sophisticated program intersection protocols and collaboration opportunities, the APTOS have reinforced program boundaries and the one dimensional, transactional approach of the old disability systems. In doing this, the APTOS have made it more difficult for people using the NDIS concurrently with other programs to get the ‘joined up’ services they need. The APTOS have been neither reviewed nor amended as the scheme has evolved. Rather than a level playing field of program responsibilities, their existence has entrenched the historical divide between programs and ensured program interactions focus on who pays, rather than the needs of the person with disability requiring their concurrent support.

- Young People in Nursing Homes National Alliance 50

The risk of negative safety and wellbeing outcomes are exacerbated for First Nations people, particularly for First Nations women. There is inconsistent education, understanding and knowledge of First Nations concepts of disability and care, ways of being and cultural obligations. This inconsistency undermines efforts to improve outcomes for First Nations people with disability, resulting in real harm to Australia's most systemically marginalised population.

Lack of communication between service providers and communities is evident and a huge problem in supporting mob with disability

- First Peoples Disability Network 51
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There remain significant problems with how the NDIS interacts with specific mainstream service systems

When issues occur at specific intersections of the NDIS and mainstream services, this can create confusion and ambiguity for participants. At best this is frustrating and time consuming. At worst it can put the health, wellbeing and safety of people with disability at significant risk. Despite being the subject of repeated calls for change over the last ten years, the problems remain significant. We have heard about challenges that remain unresolved at the interfaces between the NDIS and the transport, child protection, justice, school education, hospitals, aged care and mental health systems.


Transport is an essential enabling function for people to live connected, productive, and fulfilling lives. Notwithstanding the slow progress to full accessibility in public transport, the NDIS has a vital role in providing transport supports for people that cannot use public transport due to their disability.52

However, the lack of a clear long-term NDIS transport policy and continued reliance on the Australian Government’s Mobility Allowance means the assessment and funding of transport supports is not tailored to participant needs.53 This has led to inconsistent decisions, insufficient funding in plans, inequitable outcomes, and an overreliance on cross-billing arrangements with state and territory taxi subsidy schemes.54 Opportunities to potentially leverage community transport networks to better support all people with disability have also been missed.

Child protection

All children have the right to live in a safe family environment. Sadly, children with disability are less likely to have placement stability, are more likely to live in non-home based settings, and are more likely to be at risk of experiencing harm.55 We have heard of inconsistencies in service provision between the NDIS and child protection, with children and families caught between the two systems while disputes continued about who should provide support and pay for it.56

In addition, poor collaboration between the National Disability Insurance Agency (NDIA) and state and territory agencies means information sharing via the NDIS portal is not consistent, there is duplicative and unintegrated screening and risk assessments, along with inconsistent planning and coordination for complex situations such as when a young person transitions to life after care.57


People with disability, especially those with cognitive and psychosocial disabilities, are overrepresented in the justice system. In 2018, the Australian Institute of Health and Welfare found that 29 per cent of the Australian adult prison population had a disability.58 95 per cent of First Nations people who appear in court charged with criminal offences have an intellectual disability, a cognitive impairment or a mental illness.59

We have heard that the contested responsibilities when delivering supports to participants who interact with the justice system means supports can cease or be denied when participants enter custody or remand.60 There can also be disagreement between the NDIA and justice systems over whether certain supports are meeting needs arising as a result of a functional impairment or needs arising as a result of offending behaviour.61 This disagreement is complicated by the fact that the two categories of need have a complex relationship that is difficult to distinguish between,and have been left open to interpretation in the National Disability Insurance Scheme Act 2013 (NDIS Act), NDIS Rules and the APTOS.62

As with the child protection, mental health and hospital interfaces, we have heard of the difficulties arising due to the absence of specialist case management and integrated planning and funding arrangements.63 This is a long standing and critical issue as participants who interact with the justice and youth justice systems often have complex needs that need to be met by multiple state and territory agencies and the NDIA working together.

Early childhood and school education

Slow progress toward inclusion affects all people with disability but has a profound impact on the life trajectory of children and young people. Failing to include children in the early years can set them on what Inclusion Australia described as the ‘polished pathway’ to lifelong segregation.64 Inclusion in early childhood education and care is crucial for later outcomes and a strong transition to school. However, participation rates are low for children with disability and developmental concerns and transition to school is often poorly managed.65 This can have devastating consequences such as isolation and poor educational outcomes.

The NDIS can exacerbate this exclusion in schools. Its individualised approach often fails to integrate with the classroom experience, and can undermine inclusion for children with disability. This approach also creates perverse incentives whereby some students only receive supports in class if they are a participant, even though schools are provided funding (through disability loadings) for meeting the disability needs of their students.66

Families and young people continue to report a lack of support, exclusions and barriers to receiving an inclusive education experience.67 We have heard about the high levels of school refusal, home schooling and even no schooling for children with disability, particularly children who are neuro-diverse. This impacts on lifelong outcomes and increases reliance on specialist supports provided through the NDIS.


Despite recent efforts driven by Disability Reform Ministers and the NDIA, including the introduction of Hospital Liaison Officers, we have heard that significant delays when discharging some participants from hospitals remain a problem.68 This occurs when participants in hospital inpatient care are medically cleared for discharge but have no safe destination available outside of hospital. As a result, participants must remain in hospital until appropriate supports are available. This comes at a great cost to the participant and the wider health system, leading to worse outcomes for the participant, fewer inpatient beds for other patients, and longer waiting times for ambulances and elective surgeries.

In addition, we have heard about a lack of clear discharge and transition plans, poor communication and information sharing between the NDIA and health systems, inconsistent decision-making and drawn-out NDIA planning procedures with barriers to completing plans (such as waiting on specialist advice and assessments).69 As with the mental health system, the effective provision of concurrent supports within hospital settings can be marred by inconsistent understanding of responsibilities and poor working relationships.

There is a need for more step-down facilities, when people with disability leave hospital, because while they are ready to move out of an acute medical setting, they are not ready to move home or their long-term support and living needs may not be clear.

Aged care

As all people age, the likelihood they develop disability or further disability increases, and their support needs may change. However, the NDIS was never meant to replace the aged care system - they were meant to work together.

Under current legislation, when a participant turns 65 they cannot access more intensive aged care supports, such as the 24/7 nursing care offered in residential aged care settings, without giving up their NDIS supports.70 As the Royal Commission into Aged Care Quality and Safety noted, there is more funding per person in the NDIS when compared to the aged care system.71 This means older Australians with disability are not necessarily accessing the services that best meet their needs.

In addition, when the NDIS rolled out, the Disability Support for Older Australians (DSOA) program, now closed to new entrants, was established for some people ineligible for the NDIS due to age. While DSOA is similar to the NDIS, having two systems operating leads to inconsistencies, inefficiency and unfairness. For example, two residents in the same home can have different funding arrangements and their care cannot be effectively coordinated.

Mental health

We know that to provide the best support possible and increase the chances of recovery, sufficient and timely clinical and community services must be provided concurrently with disability supports. However, we have seen that there are too few clinicians and significant waitlists in some areas, and a shortage of community mental health services for people who need more intensive support than general practice services, but less than specialised state and territory mental health services.72

This failure of coordination between the NDIS and the mental health system contributes to poor outcomes being achieved for participants with psychosocial disabilities. The NDIA has also failed to use its significant role in mental health to influence the delivery of mental health services more broadly.

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Temporary arrangements put in place during NDIS implementation remain unresolved

During the roll-out of the NDIS, governments put in place temporary arrangements that were meant to be reviewed and resolved once the NDIS was in place. Two arrangements that are still unresolved were raised in our engagements with participants, governments and the sector.73

1) The National Injury Insurance Scheme

For people who suffer catastrophic injuries that result in disability, the Productivity Commission recommended a National Injury Insurance Scheme (NIIS) be established alongside the NDIS.74 Of the four originally proposed streams of the NIIS, only the motor vehicle and workplace accident streams were established. This has left significant gaps that push people into the NDIS. Arrangements between the NDIS and existing compensation schemes are also inconsistent, which can result in overlap with the NDIS and create additional stresses and costs.75

2) In-kind programs

In-kind programs are disability-related services funded by the NDIS but delivered by state and territory governments. In-kind arrangements are inefficient, and were intended to only be a transitional arrangement. However, delivery of personal care in schools and specialist school transport schemes continue to be on an ‘in-kind’ basis - with states and territories delivering these services on behalf of the NDIS. This ensures service continuity and maintenance of the status-quo while the long-term arrangements are not agreed. However, it has prevented reform and constrained choice and control for participants and their families.

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