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One of my little eccentricities is that I like playing around with words. And with the huge array of new acronyms spawned by the NDIS, there has been plenty of scope to invent new phrases for what they could mean! ILO, of course, stands for Individualised Living Options in the NDIS world, but It’s Like Onion could also apply.
It’s like being in your local Bunnings carpark at 11.30 am on a sunny Saturday morning. You open your car door and there’s the irresistible scent of onions caramelising on the BBQ beside the front door.
And at first glance, the Individualised Living Options Operational Guideline (OG) is like the onions. It smells good! It makes you want to say, “Yes please. I’ll have one of those!” And just like the Bunnings sausage in a bun, if they get it right, it could actually taste pretty good, too. But if the wraparound elements (like the bun) are a bit stodgy or stale, well let’s just say it might fail to meet your expectations. So, let’s peel back the layers of this OG and take a closer look.
The first thing to notice is that participants are prioritised. This OG is written to and for participants! It is well organised and is in fairly accessible English. So, well done NDIA!
It’s a bit repetitive, but given how new ILO is for many people, that’s probably not a bad thing. And the things it repeats are consistent throughout (yay).
ILO Stage 1: Exploration and Design
If you’ve been following ILO developments over the past year or two, a lot of the early explanatory material in the OG won’t be new: What is an ILO? Who is ILO for and who isn’t it for? How is it funded? And what is in and out of scope?
The OG also confirms that Stage 1: Exploration and Design is here to stay. This is the stage at which a person with a home and living goal will thoroughly explore what their ILO options are, what sources of primary and supplementary support are available to them, and how they need their arrangement to be set up in order for it to work. There’s an overview early and a more detailed section later. And as expected, we do get some additional helpful detail.
The overview of Stage 1 finishes by describing the things to be included in the Service Proposal, which is the logical output of exploring and designing what an ILO might look like for a given individual. And – no surprise – there’s a link to a Service Proposal form which must be completed, noting (remember, this is addressed to participants) that “You must be involved in developing the Service Proposal, and we need to know you agree with everything in it.”
There are four more things to say about Stage 1. First, to even be considered for ILO funding, the person needs to have a goal to explore their home and living options. That kinda goes without saying these days. Second, the person will need to complete a Home and Living Supports Request form, so that the NDIA can “understand your support needs, so we can then discuss the home and living supports that best meet your needs”. Third, there’s some detail about what the Agency will consider when determining whether Stage 1 supports are reasonable and necessary, predictably stepping through each of the R&N elements from Section 34 of the Act. Helpfully, the value for money section states, “we will fund up to $3000/$5000/$10000 to design your ILO” and identifies the elements that will determine which band applies.
Finally (and this is a kicker that’s a bit confusing to me), the value for money section concludes by saying, “Note that these amounts are not usually added as additional supports on top of any pre-existing funding in your plan. Actual funding depends on your individual needs and often repurposes existing funding for exploring ILO, as needs and stages change.” In other words, ILO Stage 1 Exploration and Design will usually be funded by accessing the flexibility in core supports to purchase this IF they have a relevant home and living goal and meet the in-scope criteria for ILO. In practical terms, follow the reasonable and necessary section prompts to ensure the person is eligible.
ILO Stage 2: Supports
The first thing to notice is that Stage 2 is now subtitled “supports” as opposed to “implementation, ongoing monitoring and redesign.” It is, as you might have guessed, the stage where the support is provided.
The second thing to notice is that the Home and Living Supports Request form and the ILO Service Proposal are prerequisites for Stage 2 funding, and funding decisions will be based on the ILO supports identified in the Service Proposal. So, do the work needed to get that right in Stage 1. It includes a cost estimate for the ILO service.
Third, and predictably, the funding decisions will then be based on determining whether the ILO supports meet the reasonable and necessary criteria (Section 34) – and the OG provides good guidance on what will be considered. The NDIA is interested in knowing what primary supports are proposed and how the supplementary supports provide flexibility and sustain the primary support.
When discussing the value for money criterion, the OG provides some dollar values aligned to three levels of ILO support:
Up to $105 000/year (level 1)
Up to $150 000/year (level 2) or
Up to $230 000/year (level 3), with descriptors for each level.
Note 1: “These levels are a guide only. We decide your actual level of support based on your individual situation”.
Note 2: Social, economic and community participation supports are usually funded separately to ILO.
It’s also worth making a comment about the “Is it safe?” criterion. The OG has just one line to say that the ILO is not likely to be considered effective and beneficial if there are risks to the person or others. Given what we know about ILOs that work in WA, there may be a mountain of things to consider and address for some people during Stage 1. It will be important to be really clear about your organisation’s risk appetite and to be able to agree with the person how you can identify and address risks in ways that will work for them.
Overall, there’s a lot of clarity in this OG and a lot to like about it. It clearly aligns with the new Home and Living direction that the Agency seems to be heading in, which is a good thing. Even using the word ‘home’ is more reflective of the ordinary lives and language that most people use when talking about where they live.
Back to the onion metaphor
I can’t finish without revisiting the onion. Now, onions are used in lots of different ways, and we all have different preferences when it comes to preparing and using them in our cooking. ILOs are a bit like that too, and the OG makes it clear that that is the intention, with four lines that your eyes might slide past without even noticing. Collectively, these four lines pack a very important mouthful of flavour and are worth savouring (okay, I am probably pushing the analogy a bit too far now).
Wherever possible, decisions about your ILO should be made by you. You should be supported to be involved and make decisions as much as possible. No two people will design their ILO the same way. Everyone has their own needs and ideas about what’s a safe and happy home.
There are two major implications for providers here.
- These sentences encapsulate the BIG paradigm shift of the NDIS: people with disability – that’s ALL people with disability – now get to make THEIR OWN DECISIONS, including decisions about the supports and services they receive. This is in the NDIS Act and has implications for all service providers, support workers, parents and family members, bureaucrats and policy makers. So, to succeed at ILO (and in the NDIS broadly in the long term), you as a provider need to shift decision-making authority to the person receiving the services (parents of adult NDIS participants now face the same challenge too). For most established providers (and some new ones), this is a significant cultural and operational challenge and should not be underestimated. You’ll need to be able to operationalise a strong commitment to some pretty specific core values. If you’re not yet ready for that, your first step on the ILO journey will be to start that process. Please come and talk to us if this is you. We can help with this.
- Because no two people will design their ILO the same way, you can’t set up and run an ILO program!!! If you want to deliver ILO supports, you need to be able to work with one person at a time in an intense yet affordable way. And that is going to be messy and ambiguous at times. Leanne Pearman, co-CEO of WA’s Individualised Services, describes this as “working in the grey”.
For providers new to or considering ILO, do a sober assessment of your readiness and capacity to offer and deliver ILO. Make sure you get your head around the way that primary and supplementary supports work together in ILOs, noting for now that primary and supplementary do not directly correspond to paid and informal (or unpaid) supports. And in many ILOs, some funded supports will not be paid at an hourly wage rate.
Providers understandably think in terms of paid services, business and service models, policies, procedures and systems. In reality, many people and families have been socialised to think similarly when interacting with “the system”. ILO requires you as a provider and the person (and their family or supporters) to begin with what’s an ordinary understanding of home that works for everyone. Together, you will explore what that might look like for each individual.
