Summary of DSX’s position

1.      DSX supports the Government’s move to commission quality, independent Support Connection & Coordination (SCC).

2.      Such commissioning must occur at the SA3 level, equivalent to 367 regions, with an average population of 75,000, and NDIS participants of between 1,500 and 2,000.

3.      The starting point for design of the new SCC function must be high quality, independent* Support Coordination, not the current, flawed partner-in-the-community LAC model.

4.      * ‘Independent’ in point 3, requires the SCC contract holder to not have any other contract or paid role elsewhere in health, disability or aged care i.e. the future SCC’s do nothing else, ever.

5.      All people with disability, including those who are deemed ineligible for NDIS, should have access to SCC, in order to deliver on the original intent of NDIS to provide navigation support to every Australian with disability. (See point 6 re how this can be funded.)

6.      The Government’s assertion that intermediaries cannot advocate for participants is flawed. A good, independent Support Coordinator supports a person to navigate complex Government systems and NDIS marketplace choices and to build the person’s capacity to make informed decisions on their own in future. Removing advocacy from SC would significantly devalue the role’s purpose.

7.      Human SCC’s can be much more efficient and deliver greater value for money with an AI-powered virtual navigator, that would save significant time spent by a Support Coordinator in getting to know the individual and exploring service options. This will enable more people with disability to access a SCC without increasing the total cost to Government.

8.      Good, independent Support Coordinators cannot wait until 1 July 2028 for appropriate pricing to be introduced; it must be indexed now. Some independent Support Coordinators have persisted with an ethical, employment model for their SC staff, however they are now losing money due to seven successive years of price freezes.

9.      Any quality, registered Support Coordination business that is excluded from the future market by virtue of failing to secure a contract from 1 July 2028, should be compensated for any losses so incurred.

10. Support Coordinators are often required to undertake additional report-writing or other administrative tasks by NDIA that is unfunded e.g. Crime Commission, Quality and Safeguards, DCJ Reporting. For existing SCs, this must be remunerated on a per hour basis to prevent SC businesses from becoming insolvent.

Key flaws in current NDIS service intermediation

The current NDIS service intermediation process is badly flawed, notably:

·       Quality is inconsistent - it is estimated that as many as 6,000 of an estimated 10,000 people who currently call themselves ‘Support Coordinators’ are not equipped with the minimum level of knowledge, experience or competency that should have been stipulated as mandatory as part of intermediary registration.

·       Independent intermediaries are in the minority – as many as 8,000 of the current Support Coordinators are not independent (e.g. employed by an organisation that is also a service provider), giving rise to a conflict that undermines the entire premise of ‘choice and control’ for participants, and should never have been allowed.

·       Local Area Coordination is delivering very little value, according to participants - see Appendix 1 LAC survey.

A majority of NDIS participants have some degree of cognitive impairment, but we have built a system (NDIS) that cannot be navigated by this cohort, not even vaguely. For this reason, all sharp practices, conflicts and coercive behaviours need to be removed from the NDIS ecosystem in order to level the playing field and uphold quality & safeguards.

Currently, we are witnessing significant ‘consolidation’ behaviours by some registered Support Coordinators, involving them picking up the pieces from failed, ethical SC’s who can no longer sustain an employment model. Taking advantage of this by pushing SC’s into a consolidated Contractor model, is unethical. We do however acknowledge that many of the best, independent Support Coordinators have transitioned to a contractor model purely to survive. We see this differently from the current race by larger SC businesses to consolidate using the contractor model. Our members who currently utilise contractors, are committed to reverting to a 100% ethical employment model from the time that hourly Support Coordination pricing is appropriately indexed.

Features that must be present in the new SCC system

Good, effective SCC can be delivered where each of the following features is present:

·       Participants are able to choose a SCC who works for a SCC business in their local community, with deep connection to and understanding of that community

·       Participants are able to express their individual needs and preferences as part of being matched with a SCC, and can request a new SCC where they are unhappy with their current SCC

·       Participants are able to choose whether face-to-face, video call, telephone or email is their preferred means of communication with their SCC

·       Each SCC possessing a ‘SCC passport’ that is visible to participants – this connects to a SCC competency and experience database

·       Prior to 1 July 2028, mandatory training provided to all SCCs by a commissioned expert panel of L3 Support Coordinators, being AHPs who are familiar with complex cases spanning health, housing, justice, child protection, Centrelink, office of the public guardian etc

·       SCC is regarded within the disability sector as a highly valued profession

·       SCCs undertake mandatory ongoing professional development

·       SCCs are rewarded and supported appropriately, minimising turnover and therefore disruption to participant’s lives

·       SCCs are held accountable for outcomes delivered to the people they support

·       SCC basic caseload not more than 50 participants, SCC+ caseload not more than 12 participants

·       Participants are able to choose a virtual SCC where their preference is not to deal with a human SCC

Appropriate advocacy vs inappropriate adequacy

Good, independent Support Coordinators currently advocate strongly for the participant if/when they are being let down by providers. The importance of this role cannot be underestimated, and extends to identifying and reporting on fraud, neglect and abuse. Good Support Coordinators will smell a rat long before a formal complaint reaches the top of the NDIS Commission’s investigation queue.

Good, independent Support Coordinators also advocate for participants to access the mainstream and community support they are entitled to.

DSX suspects that the Government’s statement around SCs not being entitled to advocate, is related to conflicted SCs who act as a sales pipeline to services being sold by the same (or a related) entity. Ensuring that the future SCCs are 100% independent removes this risk.

Under the future SCC role, the Government may wish to consider whether a SCC is able to advocate for a person who is believed to have an NDIS plan that is inadequate. The Government may consider putting in place a rules that in such cases, the SCC would be required to alert an independent advocate, who can progress the question over whether the person’s funding is at an appropriate level of funding.

Better triaging of SCC needs

At present, approximately 2 out of 5 NDIS participants have access to a Support Coordinator. It is believed that tens of thousands of people who would benefit significantly from a Support Coordinator, do not have one. Our Members know this because they are continually approached by NDIS participants seeking support, however those participants do not have support coordination funding.

As part of the design of the new system, there must be a more consistent and participant-specific assessment of a person’s life circumstances to determine their suitability for SCC, including:

• complex or changing support needs;

• interactions with several service systems;

• limited or no informal support;

• communication or decision-making barriers;

• homelessness or housing instability;

• acute/episodic psychosocial disability;

• entry into or discharge from institutional settings;

• limited local service availability;

• cultural, linguistic or racial barriers;

• refugee or humanitarian settlement experiences;

• family violence, abuse, neglect or exploitation;

• drug or alcohol dependency;

• a high risk of disengagement.

The NDIA should not restrict SCC to only the participants it considers most complex.

Earlier navigation can prevent crises and reduce the need for intensive intervention.

Within the SCC+ function, there needs to be significant training in the nuances of ‘Home & Living’ including ILO, host, co-resident, granny flat, intentional community, concierge, drop-in + informal etc. Innovation in home & living is common in Western Australia but not well understood elsewhere.

SCC competencies

In addition to an understanding of the wide range of disability and impairment types, and the degree to which they impact on a person’s capacity to achieve their goals, and how those impacts might best be mitigated, every SCC should demonstrate:

• knowledge of the NDIS Act, rules and operational processes;

• human-rights and supported decision-making practice;

• cultural safety and cultural humility;

• trauma-informed practice;

• understanding of minority cohort experiences including Aboriginal and Torres Strait Islanders, migrants and refugees, people exiting prison or hospital, LGBTIQ+;

• an understanding of how to support participants and families to leverage informal, mainstream and community services, in some cases as a primary support system i.e. in preference to NDIS;

• capacity to recognise abuse, neglect, exploitation and service failure;

• skill in coordinating across organisational boundaries;

• competence in working with interpreters;

• clear communication anAOd accessible-information skills;

• understanding of gender and intersectionality;

• professional boundaries and conflict-of-interest management; and

• capacity to challenge system barriers without imposing values on participants.

The importance of local, community-based

SA3 regions should be the basis for commissioning SCC, as the higher level SA4 grouping joins together diverse regions, each with unique circumstances and needs.

Local knowledge will be a key criterion for commissioning, showing demonstrated knowledge of:

• local disability service providers, including:

  • knowing who the key personnel are;

  • the providers’ strengths, weaknesses and nuances;

  • providers’ recent performance;

• local government inclusion program and community facilities and services;

• local health, housing, education and justice systems;

• local transport and geographic barriers;

• local ethnic, cultural and language communities (including First Nations);

• informal and community support networks;

• referral pathways across regional boundaries.

AI-based virtual navigation

AI-enabled virtual navigation will play 2 key roles:

a.      Present a succinct summary of the person’s health/disability life experience to a new SCC i.e. avoiding the need for the participant to tell their story all over again. This may be achievable for 80% of participants and will significantly reduce the time required by a SCC to understand the person’s history; and

b.      Allow participants who have had traumatic experiences in dealing with and/or trusting humans, to opt for a virtual navigator. This may be chosen by up to 10% of participants.

Our vision for a vibrant new SCC

We have envisioned what the Government’s vibrant, new, participant-focused SCC system looks like.

·       No longer is a SCC a person with a job title but nothing to back it up. In the new SCC system, every SCC is a professional, their competencies are transparently recorded in their SCC passport, and by July 2029, they are regarded by participants as the most trusted partner in their lives.

·       One or more Cooperatives of SCCs collectively win some of the SA3 region contracts. Collaboration delivers better outcomes for participants and for the Australian taxpayer. Small, community-based SCC businesses that form together in a Cooperative, will be stronger as a collective and together can deliver outstanding outcomes for their respective communities.

·       Members of at least one* of the Cooperatives utilise an organisational super-brain as a support tool for use by SCC’s, using sophisticated, longitudinal data including impairment type, environmental circumstances, prior NDIS consumption, outcomes achieved etc. * Note that some DSX members who currently deliver Support Coordination are already planning to form such a Cooperative.

·       A new, free, fully-featured provider directory (like the one DSX has built) is used by all participants and SCCs. This directory is error-free, always up to date and carries none of the flaws of the plethora of fee-for-listing directories currently relied upon by participants. The combination of tech and data quality will deliver to Government the much-needed value for money objective.

·       The future SCC+ practitioners, equivalent to today’s L3 Support Coordinators, comprise mainly* allied health professionals, ensuring that appropriately qualified individuals are supporting those with the most complex needs. This needs to be funded at a level much higher that approximates that of Behaviour Support Practitioners. SCC+ practitioners work in a highly stressful environment, requiring intensive focus, ongoing learning and development, clinical supervision and respite from the role; the only way to ensure quality is to reward SCC+ practitioners appropriately.
* In remote regions, where no allied health professionals are based (rather, communities rely on locum/FIFO therapy services), it is imperative that SCC+ is able to delivered by appropriately skilled and experienced non-AHPs. This will deliver a more appropriate expert, locally-informed support than a remote/video-based AHP in a metro area.

·       Every SCC understands the full range of escalation pathways, with warm hand-overs ensuring that no participant is ever at risk of slipping through the cracks

·       Appropriate SCC+ funding is attached to any person experiencing complex, intersectional challenges including poverty, homelessness, incarceration, alcohol and illicit drug dependency, DCJ children leaving out of home care etc. The SEIFA index and other Government statistics can be used to identify participants in SA3 areas where these conditions are more likely to be experienced.

·       From 6 months prior to the cut-over to new contracts, all NDIS participants are informed that if their current SC does not meet the new SCC criteria (i.e. independent, minimum quals/experience/competency), they will need to shift to a SC business that meets the criteria asap. Where a person’s current SC meets the minimum standard or they shift to one that meets the standard, NDIS participants are given the opportunity to connect with the same SC, if they end up being employed by one of the successful tenderer SCC orgs - no guarantee, but at least an opportunity for continuity of supports, to avoid a huge spike in separation trauma post 1 July 2028.

Current spend on Support Coordination

Support Coordination Level 2: Coordination of Supports               $998,948,000

Support Coordination Level 3: Specialist Support Coordination              $117,922,000

Support Coordination Level 1: Support Connection                         $     2,255,000

The total NDIS spend on support coordination in the 12 months to 30 June 2026 equates to approximately:

·       9,400 Support Coordinators delivering 24 hours of SC per week for 44 weeks @ $100/hour

·       600 Specialist Support Coordinators delivering 24 hours of SSC per week for 44 weeks @ $190/hour

Who is DSX

DSX (Disability Services Exchange) is a coalition of small to medium registered NDIS providers committed to ethical service and transparency for the benefit of consumers.

DSX was established by, and is run by, people with disability, for the benefit of people with disability, frontline workers and the thousands of small, registered, community-based providers that make up the vibrant NDIS marketplace.

One of DSX's primary goals is to democratise NDIS data so that participants have better information to make informed decisions. The www.dsx.org.au platform is free to use.

This submission has been prepared by Members of DSX. Enquiries related to this submission can be emailed to Brendon Grail, DSX Coordinator at brendon@dsx.org.au 

Appendix 1 LAC survey results

Is there any further information you would like to share about the quality of support you receive from your LAC - good, bad or indifferent? (Please do not mention a person's name.) 69 responses (unedited)

We do not have a LAC in my region. The closest is 300 + kms away. Our support coordinator is brilliant. She has supported us in connecting with community, mainstream and NDIS supports and is always quick to respond when contacted. Her assistance is invaluable to us.

You ring the LAC and they either don't answer, you can sometimes leave a message or it goes to the national line and they can't help. No one reaches out to see how you are going. They dont' care. I need Support Coordination

It is impossible to contact your LAC, let alone get a response from someone else in the office. Oftentimes they are rude and either tell me to contact the NCC, or tell me incorrect information or say they received information from the NDIA but refuse to pass that information on. I’ve also been told that I am lucky to have a child on the scheme with some funding and that it was my choice for children so I should suck it up and be a parent. Nevemind I have a 21 year old who displays challenging behaviours and I am regularly a punching bag. No compassion and no understanding of how to help. SC has been tremendous. Saved me from the cliff edge many times

Not enough power

I have never met my LAC or spoken to them - My SC had their funding reduced because I have an LAC but the LAC does nothing

Haven’t had any contact at all as plan was rolled over for the year

My support coordinator knows me and my needs but the LAC cannot provide any specific information about services or my plan.

Lac never assists with any issues

LAC is as helpful as tits on a bull! Can't get in touch, can't help like I need because they don't get enough money to do the work apparently so I haven't got any support in and no one helps

My Lac is useless and doesn't help me at all

I’m answering this as a provider assisting my participants many times to get assistance/connect with their LAC’s

While he’s an extremely nice person I wish that we were able to contact directly, rather than go through generic phone lines or emails and wait for calls back. Wish that they were allocated someone who knew about our specific disability so that they could do referrals or recommendations to services

We couldn't do this without them!

LAC’s show you where the provider list is but do not know what providers are experienced in what you need help with. They expect you to just have someone random without providing background and this equals many phone calls and leg work to source the right provider. When you have a support coordinator they know exactly who to contact if they are a good one.

No

No support or consideration

LAC's in my experience have not been helpful at all

These are completely different roles. In 10 years I have not had the same LAC, apart from 1 year I have not been able to contact them. Often requiring an appointment weeks later to receive a phone call.

I met with my last LAC once and it took 6months to get that intro. I was so heavily gatekept from them they kept insisting i had to go through another one 200kms away. I never heard from them again. 2yrs later i got a call from uniting asking me about it and was confused when i said they were mia. I have no LAC anymore. All LAC functions go through a contact at the NDIA itself to a person who i only speak to in emergencies and plan reevaluation meetings. They are not local and my plan has simply been auto rolled over since the last eval 4yrs ago - i havent spoken with her since. I would suggest that my support coordinator is the entire reason im able to utilise my plan at all. I am very very grateful that my NDIA person gave me the plan i needed and continues to roll it over behind the scenes. Thats the only known (but crucial) function ive come to know of an Area Coordinator local or otherwise.

My current local LAC is easy to contact and responds to my questions. Also support coordinator has been a huge help in navigating supports and services.

The lac changes all the time

We have not met yet local service coordination yet. Only our coordination we met.

Inaccessible. Unqualified. Not informed. Not up to date with legislation, my details, my current circumstance (didn't know I was in the tribunal!!!, no idea about my plan extension let alone dates etc etc

Caseloads are too high to actually help support people

They seem to hate their jobs and hate participants, have zero interest in helping anybody, and actively give incorrect information (leading to harm) and stonewall when assistance is requested.

I was taken advantage of by my support worker. He was my gardener but then said he could do support work. He made me believe we were in a relationship, got me back on drugs, and then ghosted me. I contacted my LAC and the didn't do anything about it. I contacted my Plan Manager and they reported it and also followed up with my LAC numerous times asking why she didn't do a welfare check or do anything about it. I got more help from my Plan Manager. They also provide SC in their business so if it's anything like that, I would feel much more supported with an SC.

My LAC changes so frequently I’m told and I never know who they are and they don’t help me. I always go to my support coordinator and get answers and help.

My LAC triggered a plan review I didnt ask for and the planner advised that I would have been in a worse position if I didnt seek the advice of my Support Coordinator.

There is no contact from the LAC in 6 years unless I reach out. She recently called for the first time EVER!! Asked how everything was going, when I told her she asked ‘Is there anything else I can help with’ she never helped with anything. LAC’s are getting paid money to do nothing but a check in call. I get more support from a not for profit SC company who took me on non billable, everything has been sourced myself with no help from the LAC

We have never connected with a LAC, SC has gone above and beyond

In my experience my support coordinator has been extremely supportive abd helpful. My LAC never contacted me and when I'd call the person had always changed abd I had to make a time for a call back which is not helpful when needing something. They could never do what I needed help with but my Support Coordinator could.

My LAC in particular is lovely. The one prior was terrible - uncontactable, poorly informed, no knowledge of disability or services.

LAC has disappeared and no contact for months

LACs rude arrogant, never available and when it comes time for reviews gaslight and useless. More risks to my disability due to LAC. My SC was always there when I needed them.

While my LACs have been lovely people who genuinely want to help, there tends to be a limit in what they can provide. More often than not it’s links which can be googled ourselves (though I know some may not know how to find these). Many of us have experienced trauma and purposeful misinformation and misleading from NDIA staff so LACs still feel too connected to a system that we have to be weary doesn’t have our best interests at heart. Being able to choose the person is also great because sometimes you simply don’t gel with another and it’s a very intimate sort of support that requires a close relationship particularly if you don’t have informal supports.

Lac have way to many participants on their case load to effectively do their job. Huge staff turn over so I feel like I have a new LAC every few months and never know who I’m supposed to be contacting

When returning in to mainstream proda in 2023 from the very remote online team I was never allocated or connected with a LAC and when reaching out to my local LAC team to assist me returning into mainstream where I have lived before they didn’t know how to do that and it took a long process with the ndia to do it which resulted in never having a place since remote coded to be avalible for a LAC to pick up. I found the LAC process somewhat inaccessible physically when setting up our first plan in early childhood intervention the building couldn’t accept a wheelchair and they were not trained to know how to interact with non verbal hearing impaired people but it was nice to meet with someone face to face in the first stage of having a first plan. I’m yet to see value in the support coordination system for a child with rare and complex disability when ever we reach crisis they cannot be relied upon I’m looking forward to change.

Had no support other than a plan review interview

In 5 years I haven’t had a LAC longer than 6 months, they don’t reach out or return phone calls, the don’t know other services than the ones listed on a sheet of paper. They can’t get my basic approved services connected, they don’t have time for me, I can’t run my own plan, they don’t help me work out what is in my plan, they sit on the fence with any direction. They don’t give a straight yes or no. My LAC office is horrificc

LAC does not have the capacity to provide the level of support I need

LAC case load is too big locally. Which makes it hard for them offer the level of support they can give

None

Didn't hear from any LAC for approx 4 years. Plan rolled over, when I had issues with an unplanned review was originally helpful then radio silence. Not a pleasant experience

Our experiencing initially attempting to access the NDIS through our LAC was a complete nightmare. It took nearly a year to get close to accessing NDIS. It wasn’t until I got the assistance of a friendly support coordinator who helped me find a better LAC and ultimately expedite the process that we had any success. .

My LAC would just give me phone numbers to call and not offer help. I can’t call people, I shut down when I have to speak on the phone. When I told them this the response was “not my problem”. I wish they would give my coordinator funding back because having someone who would actually come and see me in person was so much better for me.

I have not received support from an LAC, our suppprt coordinator however is wonderful, goes above and beyond

I've not heard from my LAC for 5 years.

My Support Coordinator has been with me for 10 years. The LAC has less qualifications, lack of relationships with me, and no local knowledge. I don’t understand why you would get rid of my qualified Specialist Support Coordinator to help me and replace this with inexperienced LACs.

My support coordinator had been very helpful and supportive. I am unaware who my LAC is

Their model where they’re allocated 209 clients each but only service 20, is wasted money. Because those 20 aren’t even supported properly. SC can change lives.

My support coordinator is excellent at her job. She's easy to talk to and really supportive. I've known her for quite a while and we get along really well.

Having Expert Support Coordination to use funds optimally for my son who is a NDIS participant imperative to his whole life existence. I am unable to do this on my own, having no other family, friends or the knowledge and time to navigate such a complex system.

I had some paperwork to complete and lodge with the NDIS, the supposed LAC gave me the completely wrong information and failed to up load the paperwork I had provided. This was not only unhelpful, it was also extremely stressful. This meant much time wasted trying to contact the NDIS as to why they hadn't received the paperwork and then to be told the information given to me by the LAC was completely wrong, and no-one knows what happened to the confidential paperwork?

I do not receive any support from my LAC, in fact didn't know I even had one ?? We are very happy with our support coordinator and would like to keep the ongoing support and care the same.

The LAC is useless to us. they are too far away and have never made themselves available to us. Support coordinator are invaluable, have local knowledge and accsesable to us almost any time.

They are part of my journey

LAC’s are good but you cannot keep them for very long. Since NDIS began have more than 5 LAC’s the last one being the longest of 3 years. Have had only 2 support coordinator’s during the same period worth their weight in gold

I don't know who the LAC is for our client, we know and work with our SC on a regular basis.

Have only just connected with a Support Coordinator so can't really answer the question above but with what little contact so far with the Support Coordinator I'd say both are important roles .

Every time I need help my LAC doesn’t know how to

You wouldn't even know my LAC exists. I have not heard from them once since the initial phone call that took months to coordinate to happen.

They are basically changing SC to LACs so SC will become as useless as LACs

My support coordinator knows us well

I used to be with a LAC then got an SC. She was so helpful and always checked in, and responded to me. I am homeless at the moment and she was helping me with housing and also SIL application. NDIS declined my review saying I can be more independent if I get a prosthetic leg. I'm a single leg amputee and happy with using a wheelchair. I shouldn't be forced to get a leg so NDIS can save money. Then NDIS gave 12 hours for my SC to hand back to an LAC who already has 400 participants and was outraged that she also had to support me, saying I'm too complex. Now watch my supports go downhill.

I have had so many LACs and some of them have never contacted me so I didn't know who they were.

Never hear from LAC, support coordinator is responsive and knows my situation and provides personalised support

I have had to educate and correct the LAC (forv1 of my children) when they have consistently given me misinformation... it has been the specialist support coordinator (for 1 of my other children) that has given me the correct information which has empowered me to dispute and rectify the LAC's incorrect information... the information LAC's provide to participants/nominees should be 100% correct, when it is not it limits the participants ability to access/engage with approved/allowed supports and negatively impacts the participants choice and control, it is not acceptable.

Our LAC and SC are invaluable

I use Empowrd, reliable, easy to talk to and supportive.