FOLLOWING the Federal Government’s decision to make registration of Supported Independent Living (SIL) and Support Coordination mandatory, PWDA welcomes the commitment from the NDIS Quality and Safeguards Commission to consult with the community.
PWDA reviewed past investigations and conducted a survey of members and the disability community. Members pointed out several major concerns, including:
- too much regulation, the risk of big companies dominating the market, and a loss of choice and control for participants.
Over-regulation could lead to extra costs and paperwork, which would hurt small, independent, and peer-led providers who offer personalised support. There’s also a significant fear that higher costs might drive small providers out of business, leaving only larger companies to meet people’s needs.
PWDA believes there are several solutions to address these concerns, including:
- A simple, low-cost registration process to ensure requirements are proportionate to provider capacity and the level of risk involved in service delivery
- Grace periods and transitional support should be provided to allow providers time to meet new requirements while continuing to deliver essential supports.
- Additional guidance, financial assistance, and administrative support should be made available to sole traders, microbusinesses, and grassroots organisations to help them navigate the registration process.
Rather than enforcing a blanket registration mandate, a targeted approach should be taken, requiring registration only where it is necessary to manage specific risks, such as in closed settings like group homes. PWDA supports efforts to improve quality and safety for NDIS participants.
However we feel strongly that, the design and implementation of additional registration needs to be done in a way that ensures any new measures do not create new barriers to access or diminish the rights of people with disability to exercise control over their own lives.
Recommendation 1:
Ensure mandatory registration does not restrict participant choice and control. Allow options for self-managed participants and participants registered for self-directed registration to engage non-registered providers where appropriate.
Recommendation 2:
Taking into account the different settings and circumstances in which supports are received, the NDIS Commission should implement a tiered approach that aligns with the level of risk associated with each service type. Including alternative compliance pathways for low-risk SIL and Support Coordination providers.
Recommendation 3:
Prohibit providers from delivering both SIL and Support Coordination to the same participant to ensure independent oversight and prevent conflicts of interest.
Recommendation 4:
Stronger monitoring and enforcement mechanisms to prevent coercion and provider self-referrals within SIL and Support Coordination services. Support participants to be able to make fully informed decisions about their supports, free from manipulation or coercion.
Recommendation 5:
Maintain participant choice and control by ensuring that self-managed participants can continue to access unregistered providers where appropriate, particularly in rural and remote areas and within culturally specific service models.
Recommendation 6:
Actively collect data on and monitor the impact of mandatory registration on service diversity and take corrective action if it leads to reduced provider competition or increased service costs.
Recommendation 7:
Consider exceptions or additional transition support for small, independent, and peer-led providers that may struggle with registration requirements due to limited administrative capacity, ensuring participants relying on these providers are not disadvantaged.
Recommendation 8: Provide financial assistance, administrative support, and clear guidance to sole traders, small businesses, and peer-led organisations to help them navigate the registration process and remain in the market.
Recommendation 9:
Work with NDIS participants, their supporters and representative organisations to co-design communications that provide clear accessible information about the changes. Distribute a structured timeline detailing when changes will take effect and what actions are required. Make sure all information is accessible, easy-to-understand and in multiple formats, including Easy Read, Auslan, audio, and plain English.
Recommendation 10: The Australian Government, NDIA, and NDIS Commission should introduce a streamlined, low-cost registration option for sole traders and small businesses to reduce administrative and financial barriers while maintaining service quality and oversight.
Recommendation 11:
Establish a grace period and provisional registration option to allow providers to prevent service disruptions for participants during the process. Provide additional support and / or allow exceptions to the proposed timeline for small, independent providers struggle to meet the registration deadlines; despite providing safe and quality supports to participants.
Recommendation 12:
Create a publicly available, accessible, up to date and user-friendly directory of registered providers, including small, independent, and culturally specific providers, to support participant choice and service transparency.
Recommendation 13: Ensure that NDIS participants are not penalised for unintentionally accessing supports from unregistered services.
Recommendation 14:
Ensure that mandatory registration aligns with broader NDIS reforms, particularly self-directed supports, to prevent conflicting policies that could restrict participant choice and control.
Recommendation 15:
Prioritise co-design with the disability community at every stage of the reform process, ensuring people with disability and their representative organisations, including First Nations communities, culturally and linguistically diverse (CALD) participants, and those in rural and remote areas, have a central role in shaping policy changes.
