Throughout 2021, we knew that significant changes were coming in the Home and Living space. But, unfortunately, the last 12 months have been dominated by uncertainty – the Covid pandemic is still here, while the concept of Independent Assessments came and went. It’s no wonder, then, that a substantial realignment of the Home and Living policy has been delayed. As a result, it wasn’t until December 8th that the Summary Report of the Home and Living Consultation Paper “An Ordinary Life At Home” was released. Hopefully, you have had a chance to relax over the festive season because now is the time to dig into the Summary Report to figure out where the policy process sits as we begin 2022.
The Summary Report presents the findings from the consultation process conducted over 12 weeks between June and September 2021. Overall, it is a genuine mixed bag. First, the good news. The paper indicates that the future of Home and Living has the potential to move in the right direction, especially with promises to promote flexibility of funding options, which will hopefully give participants a greater choice in how they structure their support needs at home.
Now for the bad news. Perhaps I’m too cynical, but there is little evidence that any of the new policy directions suggested so far will change the systemic failings highlighted in the Summary Report that continue to bedevil the Home and Living space. The terms of reference for the consultation were too narrow, leaving little opportunity to produce the wide-ranging reforms that the Home and Living space needs.
The Consultation Process
The Summary Report notes that the Agency received 447 submissions, with nearly three quarters of those coming from individuals, including me. That number of respondents is astronomical, reflecting both the uncertainty of where Home and Living is headed and the willingness of the disability sector to be active participants in the policy formulation process.
The Consultation Paper had a straightforward design and intent to garner feedback from participants, often at the expense of other stakeholders like providers and advocates. Of course, the emphasis on participant experience is welcome, especially given previous criticism, but the Agency has severely overcorrected. Consequently, the suggested questions suffer from myopia, as these examples indicate:
- Do you talk to people about how you would like to live?
- Where would you like to get information to think about where and how you live?
- What knowledge, learning, and resources could we create to help you choose your and supports?
- Would it be helpful if your informal supports (e.g. friends, family and carers) knew more about how and where you want to live?
- If your NDIS funding was more flexible, would you purchase different support/s for your home life than what you have now?
- Who helps you organise your NDIS supports? Have you ever used peer support networks or a mentor to find / access NDIS supports?
- How would you encourage providers to offer new and innovative service options?
Yes, it is essential to discuss the planning process and goal-setting around Home and Living for the participant. However, it is equally important to discuss systemic issues, like limited supplies of accommodation types, why approvals for accommodation and supports are becoming harder to achieve, and what can be done to bolster thin markets in rural and regional areas. These systemic issues must be solved first because it is only through solving these larger problems that individual experiences can be improved.
The Major Themes
The themes embedded in the Summary Report are largely self-evident, but it is still essential to acknowledge them:
- Improving access to affordable and accessible housing
- Protecting participants from conflicts of interest
- Supporting the introduction of more flexible budgets
- Increasing options to try more innovative and creative Home and Living supports
In this regard, the Agency has done an excellent job picking out the significant themes from the participant submissions. They also reflect my experiences and the anecdotal experiences of the participants I speak with.
The Feedback
These last two themes are where the Agency is looking to break new ground with the development of Individualised Living Options (ILOs). ILOs are designed to bring budget flexibility to the forefront when providing support for participants in the home, with tailored support being its chief asset. Budget flexibility will lead to greater and more informed choice and control. Therefore, it is gratifying to see the Agency emphasise flexible funding options.
In fact, the Agency’s focus on flexibility extends beyond funding. Interestingly, the report takes this concept further by acknowledging that participants want more power as consumers. For example, the Agency states that participants would like to write reviews of providers and provide feedback for others interested in using their services, essentially giving participants a leading role in market stewardship. Companies such as Clickability have already started this process. Still, this renewed focus from the Agency is a step in the right direction, as greater interaction for participants in the marketplace is crucial to choosing housing and support providers because these partnerships are typically long-term commitments.
Other areas of feedback from participants suggest that the Agency has wandered away from the original intent of the Scheme. Amongst the comments from participants (well, the ones the Agency chose to highlight) were calls to reduce the reliance on family members and other informal supports. There was also an emphasis from respondents on individual rather than group living environments and greater scope for developing more holistic Home and Living policies that incorporate other parts of a participant’s plan, such as community access. All these suggestions are excellent. There is only one problem. We have all heard this feedback before. More than a decade after its inception, the NDIS should have addressed many of these issues before now. The Agency’s choice to point out these concerns are simultaneously frustrating and welcome. Perhaps participants will finally be given more power in the Scheme marketplace?
There are also process-oriented criticisms that should have been addressed long ago. For example, Section 4.7.1 suggests training for planners and Local Area Coordinators in Home and Living processes, and that greater transparency with funding decisions is required. That participants had to request greater transparency over decision making once again is a cause for concern, particularly as the Summary Paper is not the first time this sort feedback has been received. Recent examples of such criticism include the legislative amendment consultation process and the Independent Advisory Council report into the feasibility of independent assessments.
A Long Road Ahead
A summary of the feedback from the Consultation Paper is the easiest part of this highly complicated process. The more significant challenge comes next. How does the Agency develop policies that balance all stakeholders' competing factors? Participants want a range of options to meet their needs, many of which were outlined. Providers seek certainty, which is difficult to capture because this consultation process – bizarrely enough – was not designed to address their needs. Bureaucrats want clear-cut policies for smooth implementation, which will be challenging to create when dealing with the various competing interests. Finally, the government wants to keep costs down, mainly as an election draws nearer, and this is impossible when one considers that any Home and Living policy requires significant investment.
How are these competing needs going to be balanced? Which of these factors is more important? These decisions can seem too complicated to comprehend, but driving positive change in a complex policy environment will be harder still.