Penny Paul and Luke Bo'sher recently hosted a hugely popular webinar on a Support Coordinators's role in investigating NDIS housing options.If you missed the live session, you can still purchase a copy of the webinar recording.
We know there will be many of you who are keen to know the answers to many of questions asked during the Q&A component of the webinar. Below are 10 of the key Qs & As that all SDA Support Coordinators should be aware of.
1. Has funding for Exploring Housing Options Packages (EHOP) been ceased?
The term “EHOP” has been discontinued by NDIA – however funding to identify housing goals and navigate the housing market continues to be funded by the NDIA.
Capacity building funding to search for housing is now being referred to as Investigating Housing Solutions, as far as we know it’s basically the same i.e. funding to work with a support coordinator to search for housing and to complete a housing plan, and funding to pay for relevant allied health assessments and for health assessors to work to build the capacity of participants to live more independently. Once critical difference is that there is no longer a ‘Package’ of supports.
Funding for support coordination and allied health assessments are made on an individual basis. We have a revised publication on capacity building funding to look for housing, https://www.summerfoundation.org.au/resources/looking-for-somewhere-to-live/
2. What is a Specialist Disability Accommodation payment? Does it cover rent?
Specialist Disability Accommodation is a payment for bricks and mortar. Participants pay a reasonable rent contribution (RRC) to their SDA provider.
The RRC for all SDA is set out in the Terms of Business (PDF) (DOC) page 10. The RRC must not exceed:
25% of the Basic Disability Support Pension
Plus 25% of the Pension Supplement received:
Plus 100% of any Commonwealth Rent Assistance received.
There are limited situations where a participant can pay ‘Voluntary discretionary contributions above the RRC, see pages 10 - 11.
To better understand SDA, see Summer Foundation's Guide to SDA. This guide explains what SDA payments are, who they are paid to and how they are accessed. For people who have SDA payments included in their NDIS Plan, it explains how to make the most of this funding.
3. Do all plans with SDA included also feature a SIL component?
It’s our understanding that not all people with SDA will use SIL as SIL is about sharing supports. Some people in SDA will have individualised supports. However we are recommending that housing plans that make a recommendation for SDA also include a recommended support plan (SIL or individualised) by an allied health professional.
4. Will the NDIA force a participant to seek “in kind” arrangements prior to looking at a new build if the participant does not want to live in an “in kind” property?
The NDIA are going to offer participants "in kind" first. The NDIA and State Governments have 10 days to find an "in kind" property that would suit the participant however if the participant does not want to live in an "in kind" SDA they have a right to refuse an "in kind" offer.
We anticipate that the participant would have to demonstrate that New Build SDA is reasonable and necessary and that it may take advocacy for participant’s to assert this right.
Refer SDA Rules:
Part 4 Determining the SDA Type and Location, https://www.legislation.gov.au/Details/F2017L00209/Html/Text#_Toc256000053
Part 6 of the SDA Operational Guidelines, https://www.ndis.gov.au/Operational-Guideline/SDA-6.html
Note that, at Senate Estimates in response to a question from Senator Rachel Siewert about “In-Kind” the NDIS said:
No. No participant of the National Disability Insurance Scheme will be required to live in an in-kind Specialist Disability Accommodation (SDA) dwelling if they do not wish to.
The transitional arrangements include some in-kind services for a defined period of time. The National Disability Insurance Agency (NDIA) does not participate in determining the prices that state and territory governments charge for in-kind services. Each jurisdiction within their operational policy, and quality and safeguard legislation, has a responsibility to deliver high quality services.
The NDIA recognises the need for innovative and fit-for-purpose services through the SDA pricing and payments approach. Over time it is expected to stimulate new high quality supply and increase choices for participants.
5. If exploring housing options is a goal in someone's NDIS plan, is it necessary to have allied health assessments completed? If you know the individual will need SIL funding but they haven't found a place to live yet, will the NDIS put the funds forward and leave the person with help of a Support Coordinator to find a place or will they need evidence of their needs through allied health assessments?
I would expect that for most participants there will be funding for Allied Health Assessments to assist the NDIS make a decision around reasonable and necessary housing related supports. An exception may be participants stuck in hospital who are likely to have allied health assessments.
These assessments are also the evidence for the NDIA to make decisions around eligibility for SDA. We are also recommending that Allied health professions outline the supports the participant would need to live in the recommended housing option.
We are uploading a Housing Plan Tool and a Guide to Allied Health Housing Assessments shortly, sign up to our support coordinator mail list to ensure you are kept up to date, https://www.summerfoundation.org.au/support-coordinators-mailing-list/
6. If an individual wants to apply for a group home what comes first- the application to the group home or the application to the NDIS for SDA funding? If waiting for SDA funding the participant may miss out of the group home vacancy.
That would depend on whether the group home is in a region where the NDIS has rolled out. If the group home is in a non-NDIS region, providers who are block funded may be opening up the process. Where the NDIS has rolled out you may have to go through the process of writing a housing plan and demonstrating that the participant meets the criteria for SDA.
Our experience is that most SDA providers will prioritise making offers to applicants who already have SDA in their plans. However, given there are not many participants with SDA in their plans (who aren’t currently living in SDA), most providers are making offers to participants for an SDA place “conditional” on getting SDA approved. We are also hearing that some NDIA planners require a participant to have an SDA offer before including SDA in the participant’s plan.
Note that the centralised vacancy management by state and territory governments is ending and so it is always worth approaching an organisation with a vacancy directly. The Summer Foundations is growing the Housing Hub, a vacancy listing website, https://www.thehousinghub.org.au/vacancies/
7. Can an approved SDA participant can rent in the private rental market - not having an organisation supporting them? e.g. running an independent share SDA accommodation?
SDA funding is for registered SDA dwellings only. All participants using their NDIS SDA funding must use an NDIS Provider that has enrolled their dwellings as SDA with the NDIA. Any organisation (including private landlords, people with disability and families) can register to be an SDA provider with the NDIA. Although there are strict rules about the construction date and design of housing to be enrolled as SDA. It’s unlikely that a private rental market property will meet the NDIS’ SDA design requirement.
New build SDA is market driven, a market is gradually developing and participants are tenants. It is possible for NDIS participants with SDA to live together. This is determined by the building design, for example each bedroom and the bathroom have to comply with the design category that each participant has been funded for.
Participants who do not have SDA in the NDIS plan, or choose not to use this, can live in any dwelling they choose and there’s no NDIS registration requirements for their landlord if they are not receiving SDA payments.
8. Who is responsible to do the SIL quote to help with landlord’s request?
The participant is responsible for getting the supports they require to live in SDA funded in their plan (Whether individualised or SIL). Some landlords may assist participant with this process to fill vacancies and access the SDA payments; but this would be an individual business decision by the SDA provider.
9. What if it's just age appropriate for the person to move out and they need a high degree of support that their informal network shouldn't have to provide?
This will be a huge area for the NDIA and a real test of ‘choice and control’. I suggest that you work with the participant to demonstrate that moving out of home is central to an ordinary life, and reasonable and necessary in terms of them meeting their goals.
For really good information on an ordinary life see, the Independent Advisory Council’s (IACs) Advice on reasonable and necessary support across the lifespan: An ordinary life for people with disability at:https://www.ndis.gov.au/about-us/governance/IAC/iac-reasonable-necessary-lifespan
10. Can an SDA provider can also provide SIL?
It was the original intent of the NDIS to separate housing from support, but this proved impractical in the rollout with “In-Kind’ group homes. The NDIA has stated in their SDA policy paper that the “NDIA expects SDA & SIL to be separable & ultimately separately provided”.
Where the same provider delivers SDA and SIL the participant is entitled to a separate agreement for each component. See https://providertoolkit.ndis.gov.au/
We are keen to see the intent of the separation of housing and support upheld, particularly for new build SDA.