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Home and Living supports are an area of NDIS policy that has always been shrouded in a bit of mystery. If you work for a provider or receive Home and Living supports, you’re probably fairly familiar with this general sense of uncertainty around how policy and planning decisions are made and what the future looks like. But recently things have gone from unclear to downright opaque.
I’m reminded of a period three years ago when the NDIA released the SDA Provider and Investor Brief, signalling some serious shifts away from the original intent of SDA. But at least then we had something in writing to validate our concerns. At present, all we have is a series of subtle and seemingly disconnected changes that are permeating throughout the Home and Living space, like the changes to SIL funding and processes and SDA eligibility outcomes that are increasingly ignoring choice and professional supporting information. But are these changes really disconnected? What is happening and why?
Specialist Disability Accommodation (SDA)
As many people will be aware, the SDA Framework, Rule and Price Guides (and the NDIS Act) spell out a range of SDA options that may be available for NDIS participants who are determined to be eligible to receive SDA support as part of their NDIS plan. Which option is suitable for a person is determined within the bounds of the NDIS Act, with regard to “choice and control” and specialist assessments as to which design category would best suit the individual in the context of the long-term NDIS goal of reducing lifelong support costs (the objectives of the NDIS Act include enabling people with disability to exercise choice and control in pursuit of their goals and the planning and delivery of their supports).
If you have been around the SDA market for a while, you will understand the rollercoaster ride it has been. However, from early 2019 through to late 2020, the market had started to show signs of maturity, and there was increasing confidence and investment in new SDA – exactly as planned. However, since late 2020 subtle changes have started to occur. Since then, very few people have been deemed eligible to live alone in SDA, especially in High Physical Support apartments, and a lot of people have been found eligible for SDA only in settings that they did not choose and that are, frankly, not reasonable. In many cases it seems that choice and control and professional supporting information are simply being ignored.
As we have progressed from late 2020 to May 2021, the subtle changes are now not so subtle. There are now hundreds of examples of people not being deemed eligible for their choice of home and receiving offers for settings that are not their choice and, in many cases, unreasonable.
It has been suggested that scheme sustainability is the reason behind the current situation and that the scheme simply cannot afford to fund people to live alone. If scheme sustainability is the motivation, then based on the NDIS data it is difficult to understand how SDA can be the problem. The latest data for SDA includes:
Total committed SDA funding: $198M against a budget of $700M
Total number of people with SDA funding: 15,667
Average SDA funding: $12,638
SDA is actually well under budget and has a low average funding level. So how could SDA be posing a threat to scheme sustainability? SDA funds the bricks and mortar of accessibility accommodation, but what about the cost of support required inside the property, particularly when living alone? Let’s take a look at that theory.
Supported Independent Living (SIL)
The data in Table P.2 on page 528 of the most recent quarterly report indicates that the total committed funding for SIL across all participants in Australia was $8.215B. That is just shy of the original Productivity Commission 2011 total cost for the entire NDIS (or Disability Care as it was referred to at that time) of $13.6B. That is 27% of all NDIS funds going to 6% of participants.
The SIL Outcomes consultation paper released in September 2020 included the following statement:
The average plan value for SIL participants is currently $340,000, and has grown by 1.3% per month from $200,000 in March 2017. This means SIL plan budgets have grown at 17% per annum; an unsustainable rate well above benchmark measures such as wage inflation. Understanding the drivers behind that increase is an important outcome from this consultation process.
We have seen the many levers the NDIS are operating to achieve some form of reduction in the average SIL package funding. These include capping prices, changes to the SIL submission processes, separation of irregular supports, counter-offers for SIL funding and so on. The last two quarterly reports illustrate that the average SIL funding is in fact declining, so the NDIS obviously found the right levers.
But how did SIL funding get so over budget in the first place? Could it be because of the, however small, number of people living alone in new SDA, especially apartments? Intuitively, you might think so. But it has been proven by many people, using the NDIS’s own SIL quoting tools, that people living alone in apartments, even with complex support, can be supported in a more cost-efficient way in this model than in a three-bedroom home, for example.
So, if it doesn’t blow the budget to fund the bricks and mortar for someone living alone or for the support required, why are we seeing a systematic reduction in the number of people funded for solo living?
The answer to this question, unfortunately, remains unclear. We appear to be at an important juncture in Home and Living and in particular the SDA market journey. The principles outlined in the Act and Rules appear to have been all but forgotten by those implementing them, which is causing significant anxiety for people pursuing Home and Living Goals and once again turning away many millions of dollars in SDA investment funding. The significant gains in the SDA market earned over the past two years are rapidly eroding and will continue to do so unless the market urgently receives clear guidance.
