A more diverse and innovative range of inclusive housing and living supports

Too few housing and living arrangements are fostering more inclusive and connected lives
Participants not eligible for SDA face difficulties accessing accommodation
The Panel’s vision: Participants should be able to choose from a range of diverse and innovative housing and living options to find what best suits their particular needs and circumstances
Recommendation 9: Deliver a diverse and innovative range of inclusive housing and living supports

Too few housing and living arrangements are fostering more inclusive and connected lives

There has been little innovation in housing and living supports, and increases in supply of Specialist Disability Accommodation (SDA) have been slow and have not always met the needs of participants.

Outdated group homes still dominate the system and, despite pockets of innovation, service models appear relatively unchanged - leaving participants with little choice. At the end of June 2023, over half (55 per cent) of SDA enrolled places were in either group homes with four to five residents or legacy stock (dwellings designed for six or more long-term residents).¹⁶⁸

A decade into the scheme, many participants who transitioned from previous disability service systems have not been given the same opportunities for more contemporary housing and living support arrangements as new participants. Close to four out of five participants receiving 24/7 living supports transitioned into the scheme from previous disability systems. These transitioned participants were almost twice as likely to have funding amounts equivalent to sharing support with more than two others (22 per cent compared to 13 per cent). For participants funded for 24/7 living supports residing in SDA, indicatively, more than two in five (44 per cent) transitioned participants lived in ageing SDA, compared with fewer than one in five (17 per cent) new participants.¹⁶⁹

While there are pockets of innovative dwelling design, we have found there are barriers to greater diversity and innovation in the delivery of housing and living supports.

Providers have incomplete and inadequate information on best practice housing and living supports, and there is limited understanding and knowledge translation of alternative, contemporary housing and living support models. Constant reforms over the last decade have diverted providers from investing time and focus in improving their service models.

We have heard individualised funding and payment approaches do not always align with the shared nature of delivery of housing and living supports, or give incentives for providers that align with good outcomes for participants and a sustainable scheme.

The NDIS’ individualised pricing structure works poorly in shared living arrangements. It prevents providers from investing in shared costs to support safety, as spending must be tied to an individual’s plan. It makes funding for supported living unpredictable, as one participant’s withdrawal from a provider can undermine the viability of supports of other residents they live with. It leads to unstable rosters that impact the ability to recruit and retain staff, and as a result, staff vacancy rates have never been higher.

- Health Services Union¹⁷⁰

We have also found current rules and procedures have led to unintended consequences. For example, we have heard about the challenges with getting home modifications for private rentals. In determining value for money for home modifications, the National Disability Insurance Agency (NDIA) takes into account whether tenure is secure and there is written approval from their landlord. We have heard that even when landlords are amenable to a tenant making modifications, obtaining support for modifications through the NDIS can be difficult.

Members have consistently reported struggles with lengthy wait times, overpriced quotes on housing modifications as well as modifications not being approved to stay where they are, which again, leads to a lack of choice and control in their living situations, not to mention safety issues and difficulty with completing everyday essential tasks. It creates housing insecurity, without a long-term view of modifications that can change over time as people’s needs change.

- Queenslanders with Disability Network¹⁷¹

We have also heard about unintended consequences of current rules within Supported Independent Living (SIL) arrangements. Currently, a participant can voluntarily exit a shared SIL arrangement with 14 days’ notice. But SIL providers cannot claim vacancy payment. This can lead to an overall reduction in the amount of support offered to the remaining participants for the duration of the vacancy and create perverse incentives for providers to fill the vacancy quickly, without regard to the preferences of the existing residents.

Filling a vacancy successfully can take some time and organisations work through a carefully considered framework which can often take months.

- Anonymous ¹⁷²

The SDA market is still maturing, but has achieved much to date, attracting a large amount of private investment and increasing the supply of specialist accommodation. Nevertheless, there is a mismatch in demand and supply. Utilisation of SDA funding is also low, and at the same time, many SDA dwellings sit vacant. As a result, the SDA market is not yet delivering the right homes in the right locations.

Participants not eligible for SDA face difficulties accessing accommodation

Access to suitable and affordable accommodation is particularly difficult for participants sharing living supports and who do not have access to SDA.¹⁷³ They get little support to locate accommodation appropriate for sharing supports.¹⁷⁴ Despite recommendations from numerous reviews and inquiries, there remains concern about ‘client capture’ where housing and support continue to be provided by one provider.¹⁷⁵ Closed system ‘SIL homes’ have emerged leading to more, rather than less, integration of housing providers and living support providers.¹⁷⁶

In our region new unregistered providers are starting up businesses, renting private homes that are not modified or fit a person's needs and taking in SIL participants with high plan funds. What happens when the rental agreement finishes, where are these people to live in this housing crisis? These providers will cease supports and they will have nowhere to live.

- Parent ¹⁷⁷

More broadly outside the NDIS, there is a lack of accessible and affordable housing in Australia. This has a disproportionate impact on people with disability, particularly those with high support needs, who are more likely to have fixed or low incomes.

Most general and social housing stock is not fit-for-purpose for people with accessibility needs. There are inconsistent residential tenancy rights for participants across different dwelling types. Widespread adoption of the Livable Housing Design Standard in the National Construction Code would improve accessibility of the general housing stock. But roll-out will take time and not all states have signed up.

The Panel’s vision: Participants should be able to choose from a range of diverse and innovative housing and living options to find what best suits their particular needs and circumstances

Ensuring greater choice for participants would require changes to how the NDIA and the new National Disability Supports Quality and Safeguards Commission (National Disability Supports Commission) set the rules and procedures for how housing and living supports are delivered. More frequent and detailed information would also support providers in delivering diverse and innovative housing and living supports.

Consistent with the findings of the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, there should be increased focus on promoting safe and effective support for participants with 24/7 support needs. A new specific Practice Standard for 24/7 living supports should be developed. The SDA Practice Standard should also be strengthened to mandate a formal separation between SDA and living support providers.

Better outcomes for participants sharing living supports could be achieved through living support providers being funded to deliver a mix (or bundle) of supports that can be appropriately shared, and being held accountable for participant outcomes. The bundle could include living supports and related supports such as assistance with shopping for household essentials.

This approach should not ‘lock’ people into shared living arrangements. Rather, it should recognise those supports that are shared at the household level and better reflect the nature of service delivery in these settings.

To ensure these arrangements work as effectively as possible, Shared Support Facilitators should assist participants to set up a service agreement, and check-in with participants to ensure the agreed service standards are being met. This would enhance participant say and choice in the operation of support in their home and improve outcomes.

Access to a new low-cost category of SDA should also be introduced for participants sharing living supports who do not require the specialist design features of other SDA categories. This will stop the expansion of closed system SIL homes operated by support providers.

The Improved Liveability category of SDA should be removed as it does not represent value for money. Following the 2022-23 review of SDA prices, the price of Improved Liveability SDA is now only marginally cheaper than Fully Accessible SDA, despite the latter having more specialised design features that can support a wider range of participants.¹⁷⁸ In implementing this change, there should be no change to the living arrangements for those currently living in Improved Liveability SDA. Those living in ageing (legacy and basic) stock, as well as new participants to the scheme, should be assessed according to their level of need and be funded for an alternative category of SDA (which could include the new shared support SDA category).

Given that reasonable and necessary funding would typically be based on an average shared support ratio of one support worker to three participants (while ensuring flexibility in line with a needs-based assessment process), there is therefore no longer a need for new SDA dwellings of four bedrooms or above, other than where this is the choice of participants.

There is also an opportunity for the disability sector to continue to work with the Australian Building Codes Board to ensure that the National Construction Code Building Classifications align with the SDA Design Standards. This would resolve the current confusion around how to classify SDA dwellings. These efforts should be encouraged and supported by governments and the NDIA.

To ensure participants are not restricted in their choice of providers, SDA providers should be separately owned and operated from living support providers. Together with broader reforms to quality and safeguarding arrangements (see Recommendation 17) and the new independent Shared Support Facilitators to support and check-in with participants, separation of SDA ownership and provision from living supports would help to address issues with client capture.

Better outcomes for participants in SDA would also be achieved through:

More flexible pricing of SDA, which would help to support more accommodation in locations where participants can build and maintain their informal support networks, such as friends, family and connections to neighbours. This would enrich lives and, over time, build opportunities for increased independence in activities.
SDA providers having better information to respond to the needs of participants.
An intergovernmental strategy for upgrading and repurposing ageing SDA stock owned by states and territories and supporting participants into appropriate housing in line with their needs and preferences.

As the NDIA and the National Disability Supports Commission implement these changes to housing and living supports, priority should be given to working with participants who have transitioned into the scheme from previous disability service systems who have never had a full assessment of their housing and living needs, goals and eligibility. Priority should also be given to those participants living with ageing carers.

Secure and affordable housing is foundational to the lives of all Australians. The NDIS alone cannot deliver this. All governments have a role to play. Intergovernmental cooperation is essential to ensure that scheme participants who are not eligible for SDA (the vast majority of participants) are supported in accessing better mainstream.

Recommendation 9: Deliver a diverse and innovative range of inclusive housing and living supports

* Legislative change required

Action 9.1: The National Disability Insurance Agency, in collaboration with the new National Disability Supports Quality and Safeguards Commission, should invest in the collection and dissemination of housing and living data and analysis. Detailed, disaggregated and tailored data, analysis and information on housing and living supports should be collected and disseminated. A more robust evidence base should inform better diversity and innovation in housing and living supports offerings and underpin more effective market stewardship arrangements.
Action 9.2: The National Disability Insurance Agency should implement a new funding approach for participants sharing living supports to strengthen the focus on service quality and outcomes. The new funding approach should be designed with participants, families and the sector. The approach should outline a set or ‘bundle’ of shared supports that should be the responsibility of the living support provider and that would ensure the provider is adequately funded and held accountable for participant outcomes, in line with the broader quality and safeguarding arrangements (see Recommendation 17).
As part of this funding approach, participants’ funding should be pooled to cover this ‘bundle’ of shared supports. To better enable pooling and to ensure adequate ongoing funding for shared supports, reviews should also be aligned for participants sharing supports and when there is a significant change in the circumstance to the group sharing, such as, one participant vacating the arrangement. Shared Support Facilitators (see Action 8.4) should work with participants to develop a service agreement with their chosen living support provider.
Shared living providers should be paid an enrolment payment, which in time could include an outcome-based payment, for the agreed period set out in the service agreement. The enrolment payment, together with regular check-in from the Shared Support Facilitator to ensure service expectations are being met, would reward providers for investing in building the capabilities of participants and their connection to community that contribute to more open settings, improve natural safeguards and could reduce the need for formal supports. With greater certainty of demand, providers might also have more stable workforces who know and understand the needs of residents and invest more in active support and assistive technology.
Action 9.3: The National Disability Insurance Agency should release more detailed and frequent information on participant demand for 24/7 living supports and Specialist Disability Accommodation (both medium and longer term needs). Data and information should be published quarterly and include current and projected Specialist Disability Accommodation (SDA) demand, current vacancies, and the features and characteristics of SDA dwellings both completed and in the pipeline. This should be complemented by information on participant preferences and best practice shared living arrangements gathered by Housing and Living Navigators (see Action 8.2) from interactions with participants. Frequent publication of detailed data should ensure the SDA market can respond by building the right types of dwellings in the right locations.
Action 9.4*: The National Disability Insurance Agency should remove the Improved Liveability category for new Specialist Disability Accommodation (SDA) developments, and review the remaining SDA categories and associated Design Standards to evaluate their effectiveness. The Improved Liveability category should be replaced by alternate Specialist Disability Accommodation (SDA) design categories which meet the assessed needs of participants. The review should be conducted in consultation with participants, the SDA sector and disability community. It should examine whether the High Physical Support, Fully Accessible and Robust categories are fit-for-purpose and enable delivery of best practice and cost-effective living supports for the diversity of SDA participants. It should also consider how the building classification system of the National Construction Code and the SDA Design Standards could be better aligned.
Action 9.5*: The Australian Government should transition responsibility for advising on Specialist Disability Accommodation pricing to the Independent Health and Aged Care Pricing Authority and introduce more flexibility to the way prices are set. The remit of the Independent Health and Aged Care Pricing Authority (IHACPA) should be expanded to advise on pricing and costing matters for Specialist Disability Accommodation (SDA) to strengthen transparency and independence in the pricing of SDA, and align with the recommended pricing arrangements for other NDIS supports (see Action 11.3). IHACPA should promote investment in the right types of dwellings in the right location. The SDA pricing framework should also be revised to allow flexibility for IHACPA to price certain dwellings above the price cap by exception. Relevant exceptions could include dwellings in higher cost locations to maintain a participant’s connection to their community, or to allow for multi-category needs.
Action 9.6: The National Disability Insurance Agency, in consultation with state and territory governments, should commission Specialist Disability Accommodation where needs are not adequately met by the private investor model. Specialist Disability Accommodation should be commissioned for participants living in remote locations, and for participants with very specialist or complex needs (such as those requiring forensic housing). The National Disability Insurance Agency should work in partnership with communities (see Recommendation 14) and state and territory governments, who deliver both public housing and specialist disability housing, to design, deliver and evaluate a pilot approach to assess how a commissioned model can deliver better supply and outcomes for participants before implementing at scale.
Action 9.7*: The new National Disability Supports Quality and Safeguards Commission should strengthen Specialist Disability Accommodation (SDA) regulation to ensure dwellings are managed in accordance with the needs of participants and mandate the separation of SDA and living support providers. Monitoring and enforcement of compliance with Specialist Disability Accommodation (SDA) practice standards should be strengthened. The legal and practical separation of SDA and living support providers should also be mandated, with limited exceptions, and monitoring and enforcement of compliance arrangements put in place (see Action 17.1). Any exceptions to the requirement should be clearly specified, for example, in remote areas where separation is not feasible.
Action 9.8: All Australian governments should agree and implement an intergovernmental strategy for upgrading or repurposing ageing Specialist Disability Accommodation stock owned by states and territories. The strategy should be embedded within the new Disability Intergovernmental Agreement (see Action 20.1) as part of the targeted action plan for Housing in Australia’s Disability Strategy (see Action 9.11). The strategy should set out timetables for upgrading or repurposing ageing (Legacy and Basic) Specialist Disability Accommodation stock and transitioning participants to appropriate housing in line with their needs and preferences. The strategy should include sensitively responding to preferences of residents and should be designed in collaboration with residents and their supporters and advocates.
Action 9.9*: The National Disability Insurance Agency should amend its change of circumstance and Specialist Disability Accommodation (SDA) policies to reduce the bedroom count of ageing SDA dwellings. National Disability Insurance Agency policies should be amended to reflect that when a participant exits ageing (Legacy and Basic categories) Specialist Disability Accommodation stock that houses more than three participants, the dwelling is able to be re-enrolled at a lower resident count - down to three residents - and funding for remaining participants is adjusted to reflect revised support ratios. This should reduce the incidence where participants are being encouraged to choose housing that does not meet contemporary standards.
Action 9.10*: The National Disability Insurance Agency should introduce a new Specialist Disability Accommodation (SDA) category for participants funded for shared living supports but not eligible for existing categories of SDA. A new shared-living category should be designed with participants and the sector to enable the delivery of best-practice and cost-effective supports for participants funded for shared housing and living supports. Funding of the new category should only cover the additional capital costs associated with providing shared supports safely and effectively. This should be offset by a decrease in any implicit capital subsidies in Supported Independent Living (SIL) packages. This should enable broader reforms for delivery of best-practice housing settings for shared living and reduce the cost of living supports over time. This would also ensure a more transparent allocation of funding for the capital component of shared living supports, strengthen safeguarding and secure a transition away from closed-system SIL only housing arrangements.
Action 9.11: All Australian governments should agree and publish a targeted action plan for housing under Australia’s Disability Strategy. The action plan should be developed by jurisdictions and include measurable actions from each state and territory government for improving the suitability of social housing stock for people with disability. This should include a requirement to build all new social housing to gold level Livable Housing Design Guidelines or equivalent. The action plan should ensure consistency in residential tenancy and occupancy rights for participants in Specialist Disability Accommodation (SDA) and include a commitment for all remaining jurisdictions to sign up to the Livable Housing Design Standards in the National Construction Code. It should also be linked to the National Housing and Homelessness Agreement and the National Housing Plan.

A more diverse and innovative range of inclusive housing and living supports

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Too few housing and living arrangements are fostering more inclusive and connected lives

Participants not eligible for SDA face difficulties accessing accommodation