Over the last few months, I have witnessed an alarming number of problematic and, frankly, confusing responses from the NDIA to submitted Housing Solutions reports. As many of you will know, the process of seeking SDA funding in a Plan begins with the Participant being funded to work with a Support Coordinator to develop a Housing Solutions report. These reports detail the Participant's accommodation history and recommend what suitable accommodation for the Participant would look like in the future. They are backed by extensive research and professional expertise. Reports are then submitted to the NDIA and, as we understand it, centrally assessed by a technical advisory team in Geelong.
To date, the NDIA has produced no documented guidelines on what exactly Housing Solutions reports need to contain. Thus Support Coordinators have been forced to make educated guesses on what needs to be included. Predictably, the feedback these reports have received from the NDIA has been (at best) frustrating and confusing. The real-life examples below have all been de-identified and used with permission.
Example 1 – Application for Robust accommodation due to violent and aggressive behaviours
"We had applied for accommodation under robust category however it got knocked back on the grounds that as per GP report her behaviours only occurred at home and they did not occur at her day program or overnight respite centre (yet). I did stress that we had to include special gyprock lining and laminate glass in the group home to cater for her aggressive behaviours as there was no certainty that her behaviours would remain under control at the group home but NDIA wasn’t prepared to accept that argument."
In this case, the NDIA would not accept the argument that the Participant needs Robust accommodation because the aggressive behaviours and property damage only occur in the home. But isn't SDA about the Participant's home? Apparently, when the family questioned this response, they were told that the Participant is not eligible for SDA because she does not have a physical disability. It is mind-boggling.
Example 2 – Home modification funding instead of SDA
In this next example, we can only assume that the Participant is being rejected for SDA and granted Home Modification funding instead. The following was included in the Participant’s Plan in the Home Modification section. The prices included do not correlate to anything in the SDA price table.
"The participant requires Supported Disability Accommodation because of their disability. The SDA costs cover the disability related housing costs that are above the ordinary costs of housing. The house is appropriately modified to accommodate living needs. Quote will be implemented following confirmation the SIL provider has registered for SDA."
In just the last few weeks, I have heard of two cases of Participants receiving this response. In this particular instance, the Participant is already living in an SDA home. I can only assume that this funding was meant for Home Modifications and is not an SDA payment. However, you cannot use Home Modification funding on an SDA approved home. If you do, the property will be deregistered. The wording of the response is confusing at best. SDA is not meant to cover the costs that are above the ordinary costs of housing. And why would the SIL provider need to register for SDA, when the house already has an SDA provider? And once again, home modifications? I truly hope that there is some anomaly in the IT system generating random, ridiculous responses (and that some programmer is currently being heavily reprimanded).
Example 3 – Mis-interpretation of SDA Rule
The final example makes me too angry to repeat in detail. In this case, a parent, after receiving assurances from multiple senior NDIA staff that it was acceptable, built a villa for her profoundly disabled son. She registered him as the owner. On the same block of land, she built a granny flat for herself to reside in so that she could be at hand to provide him with informal supports, while allowing him to live a mostly independent life. Upon applying for SDA registration, she was refused on the grounds that a parent lived on the same parcel of land.
Having a parent on hand reduced the costs of supporting this Participant by about $60,000 per year. If this is not value for money, I do not know what is. I cannot find anything in the SDA Rule about parents not being allowed to live on the same parcel of land as a Participant, if it is not the family home. Does this mean that a person with disability cannot live on Level 2 of an apartment building if the parents are on Level 10 in an open market stock home?
The above examples are just a small proposition from a growing list of unsatisfactory NDIA responses. Unfortunately, across the country, we are seeing an increasingly large group of people giving up on SDA.
How can we resolve it?
The Agency needs to take urgent action to get SDA back on track. In particular, we need to ensure that Participant planning and the approval processes are operating in a consistent, fair and transparent manner. Here are a few suggestions about how this might be achieved:
Develop and publish an SDA Participant application guide. This needs to clearly outline how SDA applications are being assessed by the Agency and what needs to be included in Housing Solutions reports. The SDA Rule talks at a high level about eligibility, but not at a prescriptive level about applications or assessment.
Educate all Agency staff, LACs, Support Coordinators and the broader NDIS community about all things SDA. On a recent road trip of NSW, it became painfully clear to me that the lack of understanding about SDA is wide-spread and frankly unacceptable.
Important SDA information needs to be released in a timely manner. It is now late August, and we still do not have a 2018/19 SDA Price Guide or updated SIL Quoting Tool.
SDA is too important to let fall by the wayside. Yet with a deficiency of urgent action, we will continue to hear frustrating examples of the Scheme letting down Participants as they search for an acceptable home.