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Submission SUB-C2L8-001882 (El B Chadwick)

Submission reference
Individual's name
El B Chadwick
Submission type
10 areas for improvement
How can we empower you through the planning process?

People with disability in hostels and boarding houses need NDIS support to access the scheme: There are many people with disability who are forgotten and need extra support in accessing the scheme, for example, people with disability in privately owned hostels and boarding houses. A very high percentage of people with disability in hostels and boarding houses have an intellectual, cognitive or psychosocial disability and many have experienced years of disempowerment and are reluctant to engage government services. They are often isolated from society, not provided with critical information about their rights and many have never experienced autonomy. There needs to be an independent support coordinator or other NDIS funded independent party who provides outreach into boarding houses. This cannot be the boarding house operator due to conflict of interest. Hostels and boarding houses are not an appropriate housing solution for people with disability as they people are at increased risk of violence, abuse, neglect or exploitation, therefore, housing conversations need to be part of early planning for people with disability in these setting. However the challenge is encouraging people with disability into the scheme in the first place, then over time, they may feel ready to consider other housing options. Many people with disability do not have family, friends or independent advocates.

People with disability who are, or are at risk of, homelessness need assistance to access the scheme: There needs to be better interface between the NDIA and specialist homelessness services, crisis services (homelessness and DFV) so people with disability do not fall through the gaps and they get the disability support they need. There have been cases where people with disability have been excluded from a service due to behaviours of concern and lack of disability supports. There has also been instances where the NDIA staff and Specialist Homelessness Services on the ground can't agree on who provides what support, meaning people with disability are not properly supported. There needs to be a significant improvement to clarify the roles and responsibilities of specialist homelessness services (and DFV services) and the NDIS, so people can access the NDIS and adequate NDIS supports while accessing specialist homelessness services. There needs to be consideration of ensuring people with disability are supported by the NDIS to maintain their tenancy when they move into housing in the community to prevent cycling back through homelessness.

Participants in group homes without an NDIS plan or NDIS Home and Living review: Many people with disability transferred directly from pre-NDIS block-funded group home arrangements to Supported Independent Living (SIL) during the NDIS transition process. Many do not have an NDIS plan in place or have not had an NDIS plan or NDIS Home and Living review. Many of them live in group homes managed by community housing providers or ngo's (sometimes these organisations also provide the support) and are left alone. They may not have a support coordinator who could initiative a review of an NDIS plan and Home and Living supports. These people with disability are left alone without knowing what is possible and not being supported to exercise their choice over who provides their supports or whom they live with as this is often determined by the support provider. Currently, the process is that people with disability must initiate a plan review, therefore people with disability in these circumstances are forgotten. Often government housing departments are aware of this, however they are not able to ask the NDIA to initiate a plan review for people with disability in these circumstances in community housing. There is a need for a rule or practice change so that the NDIS can proactively contact people with disability in group home settings (SIL) and initiate a plan review. It is not appropriate for a housing provider or support provider to initiate a plan review due to conflict of interest. Further, the support provider maybe happy with the arrangement as it doesn't impact their NDIS payment. The housing provider maybe happy with the arrangement as it doesn't impact the overall rent received.

What is the best way to provide supports for those not in the NDIS?

NDIS need to fund support coordinators or other roles that can assist people with disability to access mainstream services if they are not eligible for the NDIS. Also, more holistic planning is required to ensure that people with disability are empowered to consider their whole of life outcomes which may include a mixture of funded NDIS supports and other mainstream supports. Person-centred planning needs to be more than just about the NDIS funded supports a person is entitled to. Support coordinators need to understand the many different systems and who can, in partnership with people with disability, involve/link to mainstream supports to build a plan which is based on the art of "the possible" and be aligned with their aspirations.

Housing conversations need to happen early on in the planning process to allow people who have a housing need to properly consider their housing and living arrangements. Support coordinators need to be upskilled to have proper housing related housing conversations with people with disability or there needs to be dedicated housing support coordinators.

How you would define reasonable and necessary?

This is a significant issue and dependent upon interpretation, which is often different. There is a need to review the COAG interface principles to determine the role of the NDIS and mainstream services. The challenge is also exacerbated by the differences in practice between jurisdictions about what they consider 'reasonable adjustment'. For example, home modifications. Pre-NDIS some jurisdictions hardly provided any funding for home modifications in social housing, therefore their view of what is reasonable adjustment was much lower than other jurisdictions who had pre-NDIS home modification programs and funding in place for home modifications. It is now time to negotiate what is reasonable and necessary, based on what is reasonable adjustment under the DDA or other legislation. We need to stop basing "reasonable adjustment" on what agencies provided pre-NDIS - that is why mainstream agencies and NDIA have been unable to reach national agreement. In terms of home modifications in social housing, it would be reasonable and necessary to consider that the NDIA should fund home modifications above 'Silver' Livable Housing Design Guidelines (LHDG). This would mean that any element modification to the Silver Level in the LHDG is considered reasonable adjustment for social housing providers. There is also a need to remove the condition that housing agencies need to prove a person will be living in social housing for an x period of time, while suitable for private housing, this is not suitable for social housing.

There is also a need for the NDIS and mainstream agencies to agree ways of reducing duplication. For example, OTs determining home modifications in social housing and also for better joint working to determine placed based solutions, particularly in regional or rural areas where there are market gaps. More collaborative approaches between mainstream services and NDIA would reduce scheme costs and also reduce mainstream agency time in 'to-ing and fro-ing".

There needs to be clear communication and messaging for mainstream and NDIS providers on what is 'reasonable adjustment' and 'reasonable and necessary' to prevent people with disability falling through the gaps.

What is the best way to support children with disability… and those with emerging developmental concerns?

Further work is required in schools. How can we encourage and support people with disability (particularly ASD, intellectual disability) to better integrate with people with and without a disability in mainstream schools. In practice people with disability are either isolated or lonely with no friends or they go to the "special education unit" which can further exclude them from people without disability. While we can't force students to be friends with each other, there is a need to identify ways of encouraging friendships more, noting that teachers are already stretched. Otherwise, we will have failed. We don't want people with ASD and intellectual disability to be isolated or lonely in mainstream schools or it just creates the view that people with disability would be better off staying in a "special school" which is not the outcome that families, government, individuals or advocates want for their children.

How can the market be better designed, structured and supported?

There is a need to enact place-based solutions. No one community is the same as the other. In Queensland, due to its regional nature, there is shortages of NDIS workers in some areas, meaning people with disability have to go to another community to access supports. Fly in, fly out support services are expensive. How can we train communities to provide this support? We should look at how we can leverage staff from mainstream agencies who are visiting a particular area, for example Occupational Therapists, Queensland Health support staff. There could also be better technology interface, however it is acknowledged the internet in some areas is not good, plus people with disability may not have access to a computer, laptop or internet access.

Also housing construction prices in remote Queensland can be extremely high due to the large distances making it difficult to transport materials, adverse and seasonable weather and the availability of skilled tradespeople. All which make housing costs higher. Accessible modular housing options should be promoted - modular designs that meet Livable Houisng Design Guidelines Silver, Gold and Platinum and Specialist Disability Accommodation Guidelines could be a potential solution.

There is an opportunity for the NDIS and mainstream services to be flexible and think out of the box in terms of place-based solutions.

How would you build better outcomes or goals into your plan?

It is important that housing conversations with people with disability happen early in the planning process. It is evident that housing conversations with people with disability in government and institutional settings, including, people with disability in: long term health facilities; residential aged care; corrective services and youth justice facilities; child safety systems; and forensic disability system are happening far too late and too close to discharge. Finding housing solutions can take some time, so this does not give people with disability sufficient time to consider their housing options. Without critical early consideration of a person's housing needs early as part of transition planning, people with disability can end up remaining in the system for longer than necessary or moved into a transitional or temporary solution that is not the best solution. While transitional housing can provide some immediate relieve to Government, it can be expensive and does not guarantee a long-term housing outcome. Experience suggests that people with disability who enter transitional housing often get "stuck" there and it inadvertently becomes a long term housing. Transitional housing should not be a pathway for people with disability into housing in the community as this would be merely a cost shifting exercise and delays the inevitable - which is having conversations about a person's long term housing need. Transitional housing is an additional step that it NOT needed for people with disability who would benefit more from receiving disability supports in their home environment, rather than an artificial temporary home environment. Please eliminate transitional housing as an option for people with disability.

What does good service from someone helping you navigate the NDIS look like?

It would be reasonable to draw mainstream services into elements of NDIS planning conversations to take a holistic approach to a person's needs and aspirations. This would need to be agreed by the person with disability and their chosen advocate.

How should housing and living options be improved to build a good life?

We need to be careful with the terminology, for example "supported living and housing", "supported accommodation" etc. as this can give the impression that it housing and support are together. Whereas there is a need to separation the provision of housing and the provision of support so no one organisation has control over all, or most, of a person's life. While the NDIS ensures the separation of housing and support as far as SDA and SIL, there is a need for the NDIS Safeguards Commission to strengthen the separation of housing and support in other settings, such as privately owned hostels and boarding houses where there are many instances of boarding house operators successfully registering with the NDIA to provide NDIS supports (including personal care or support coordination etc.). There is also an inherent risk for people with disability when the boarding house operator is also a registered SDA provider, moving people with disability between SDA and the boarding house as they please. When considering registration for a provider for NDIS supports, there should be a question that determines whether the provider is also an accommodation provider, so safeguards can be put in place to ensure the provider does not deliver accommodation and support for the same participant. Safeguards can also be at risk when a person self manages their plan. I recommend that the NDIA seriously addresses and enforces the separation of housing and support (beyond SDA and SIL only) and increases safeguards for participants in these settings. The NDIS need to deliver outreach and encourage people with disability in these settings to access the NDIS and consider other housing options where they are particularly vulnerable.

A potential solution could be joint funding from State and Commonwealth (DSS and NDIA) to fund advocacy services for people with disability in hostels an boarding houses or experiencing, or at risk of, homelessness so people can feel safe and well supported in their home.

SIL should not be used synonymously with group homes. SIL is about the support.

It's time to move away from group homes. Group homes were never meant to be the 'end point'. n the early 1990's de-instiutionalisation so people with disability moving from disability institutions back with family or own their own. Many people with disability transitioned into a group home. Group homes are still being operated like institutions, albeit on a small scale. Many advocates claim that people with disability continue to experience exclusion and isolation in group homes and finding from the Disability Royal commission suggest people with disability are at increased risk of violence, abuse, neglect and exploitation in these settings. People with disability need to live in their own homes, with whom they choose and be better connected to their communities.

The NDIS should not fund transitional housing for people with disability as it is not an appropriate housing solution. It is merely a cost shifting exercise that could be avoided if NDIS planners and government agencies had EARLY conversations with people with disability living in institituional and government settings. Evidence suggests that transitional housing often defaults to long term housing and people wtih disabilty get stuck in the 'transitional' system. Paramaters and safeguards need to be put in place for the allocation of people with disability into any transitional or short-term housing solutions.

People with disability want to live ordinary lives in ordinary communities that are not viewed as "special". Congregating people with disability with high support needs together in a house can exacerbate behaviours of concern. Group homes do not foster social inclusion and can create stigma eg. "that is the disabled home". It is acknowledged that some people with disability may need to live together to pull their supports or rent costs. Importantly, people with disability want to be in control of who they live with and don’t want a support provider or landlord deciding for them. This is still happening. Disability support providers are still moving people with disability into other households without their consent - this is wrong.

There needs to be a cap on the no. of people with disability expected to live together to pool disability supports. Ideally. TWO is the sweet spot, however there should be NO MORE THAN THREE PEOPLE WITH DISABILITY expected to live together to share all, or some aspects of their support. Most people with disability could never imagine NOT being able to have a say about where they live or with whom. More than three people with disability living together together can increase stigma, reduce social inclusion and encourage people with disability to be taken everywhere together. When people with disability live together to access NDIS funding, the support provider or landlord must not be responsible for finding another tenant. If the remaining tenants do not want someone else to share their home, this needs to be upheld. Support providers delivering SIL need to consider these changes in their organisational planning. Further, if people with disability want different support providers there needs to be flexible ways of delivering this.

The NDIA need a project to pro-actively contact people with disability who transferred from pre-NDIS block funding into SIL group homes or SDA group homes at NDIS at transition that may not have an NDIS plan or had a Home and Living assessment. They are quiet, families often happy they are being looked after somewhere else, participant and family don't know there could be other options so don't fuss - they are FORGOTTEN. Group homes in community housing are becoming unviable and housing agencies need to work with NDIA to prompt plan assessments and be part of conversations around future housing and living arrangements. NDIA say they can't initiate plan reviews as it needs to be participant initiated - this needs to change in group home settings.

How should the safeguarding system be improved for a better NDIS?

Expand National and State Disability Advocacy Programs to increaser service offers for advocacy services provide independent advocacy services and legal advice for people with disability living in privately owned hostels and boarding houses and people with disability experiencing, or at risk of homelessness.

NDIS Safeguards Commissions needs to seriously consider, deliver and enforce processes, including regulatory process that enforce the separation of accommodation and support. This needs to be extended to all accommodation types, including hostels and boarding houses. The NDIS need to stop hostels and boarding house operators registering as NDIS providers and delivering NDIS Supports for vulnerable people with disability. There is a significant conflict of interest where people with disability can be fearful of their landlord. Where a person chooses to self-manage or appoint a plan manager to oversee their plans, hostel and boarding house operators do not need to register as an NDIS provider, further weakening safeguards - this MUST CHANGE.

Where there are existing arrangements where housing providers are also NDIS support providers (support providers, local area coordinators, SDA providers, plan managers etc.), the NDIS Safeguards Commission needs to put in place extra safeguards and work with the landlord to plan an exit out of the provision of NDIS funded supports.

Is there anything else that you would like to tell the NDIS Review?

Mainstream agencies should have a good relationship with the NDIA relating to the portfolio eg. housing, education, health etc. at a policy level so they can consider joint resources on particular topics, such as for Specialist Homelessness Services, Community Housing Providers, Boarding House operators.

Interface between NDIS and mainstream service systems/agencies. There needs to be less of "This is not mine, it's yours", "No it's not, it's your agencies responsibility not mine" and on it goes.

The Commonwealth could work with States and Territories and keep a repository of best practice research and resources on mainstream topics for people with disability. There is also a wealth of information and feedback that has consistently been raised through national disability reviews and inquiries. This could be captured by mainstream interface area and promoted.

While housing for people with disability is a national and state priority in key disability strategies, plans and reviews. In practice, it is not a priority. Commonwealth need to consider how they can raise housing for people with disability as a significant priority for Government housing agencies.