Policy Submission: Supported Independent Living (SIL)
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Summary and Recommendations
Supported Independent Living (SIL) is most commonly used as a mechanism for funding service providers to offer shared supports to NDIS participants in a shared living arrangement, and has enabled people living in group homes to be transitioned from government block-funded services to NDIS funded services without any change to their living arrangements.
The 2009 SHUT OUT report1 and 2011 Productivity Commission inquiry report2 highlighted that the pre-NDIS disability service system was both broken and underfunded. SIL has ensured that secure funding is in place to deliver supports to NDIS participants in shared living arrangements. However, providing more funding without fixing a broken system risks loading the scheme with great costs without delivering transformational benefits to NDIS participants. As the transition to the NDIS nears completion, there needs to be a renewed focus on ensuring the scheme delivers value for money in the long term. This means providing home supports in a way that is flexible to the needs and choices of participants, ensuring that money is not wasted on unnecessary or unhelpful supports but rather invested in supports aligned with building participant capacity to achieve their goals.
Congregate settings such as group homes are generally characterised by the features of an institution rather than the features of a home and do not deliver choice and inclusion for NDIS participants. The current default SIL funding allocation methodology encourages support provision to be locked into such shared arrangements. This constrains participants wanting to take up more flexible and contemporary arrangements and is therefore not compliant with article 19 of the UN Convention on the Rights of Persons with Disabilities (CRPD). During the current formative period in the development of the NDIS market, merely tinkering with transitional SIL structures risks entrenching existing funding and living arrangements. It is imperative to now move to offering participants on SIL more flexible support arrangements.
We therefore recommend the following:
The Joint Standing Committee on the NDIS avoid proposing process improvements that could enhance the attractiveness of SIL to service providers and thereby further entrench a model that is destined to continue to deliver poor outcomes for people living with disability.
Facilitate the national transition of NDIS participants from SIL to more flexible support arrangements through:
- allocating individualised funding to those currently receiving SIL based on what supports are reasonable and necessary for them rather than on historic block-funded arrangements
- prioritising within the ILC program investment in individual capacity-building, in relation to building a vision of an ordinary valued life, and how group homes and comparable services cannot easily deliver this
- promotion of the Independent Living Options (ILO) support arrangements now offered in the NDIS Support Catalogue service to all providers and participants, not only those already delivering or receiving ILO supports
- further development of ILO and other flexible support funding structures and pricing which use a participant’s existing funding more innovatively and do not assume co-location of participants in the same dwelling as the default
- establishing a mechanism for support providers to demonstrate support models, outside of SIL, which operate within appropriate individual participant budgets and consistent with the NDIS’s values
- establishing dedicated pathways for participants to easily exit existing SIL arrangements, including an assured way of repurposing existing SIL funding to finance more flexible support arrangements.
Ensure all participants currently in SIL receive adequate support coordination through their NDIS plan to enable them to freely choose their own living arrangements (including helping them to exit existing SIL arrangements if they choose) and choose the planning and delivery of their supports.
Require independent supply of support coordination, personal support and housing to ensure NDIS participants retain choice and control and there is no service provider conflict of interest, e.g. where a service provider (acting as support coordinator) is responsible for ensuring consistent delivery of their own services (acting as personal support provider).
Address the lack of availability of appropriate affordable housing that can lead to NDIS participants being placed in more expensive supported living arrangements:
- Escalate reforms to boost Specialist Disability Accommodation (SDA)
- Increase the availability of non-SDA housing to the 94% of NDIS participants ineligible for SDA
Where participants choose to remain in group home or other congregate settings, ensure that greater control lies with the individual:
- Allow co-residents to collectively choose a different support provider if they wish
- Allow NDIS participants to use a different provider for particular aspects of their day spent away from daily living
- Guarantee residents the right to view different group home options and meet potential co-residents before they decide if they wish to proceed, just as is in the private rental market
- Promote small cluster site accommodation over standard group homes
To read the full submission, download the accessible pdf at the top of this page.