Community Support Incorporated
Submission to the Productivity Commission Report on a
National Disability Insurance Scheme

Community Support Incorporated believes that the current income support and service system is not meeting the needs of people living with a disability and their families. There are still unacceptably high unmet needs in the disability community. We agree with the Productivity Commission’s findings that the sector is fragmented under-funded and inefficient. We therefore commend the Productivity Commission on producing this draft report.
CSI believes everyone should have a decent life and enjoy all the benefits of full citizenship.  For too many people disability exacerbates disadvantage and excludes full participation in mainstream life. This lack of inclusiveness creates tiered social strata which renders people with disability to spend their lives in the lower strata of Australian society with limited opportunities to achieve positive quality of life outcomes. This reality contravenes the United Nations Convention of human rights and is grossly inequitable. 

CSI values respect, integrity, sustainability and empowerment.  CSI supports the principle of individual client choice and flexibility with regards to the development and implementation of support services for people with disability. Therefore we welcome and applaud the development of a national disability strategy. The introduction of an entitlement scheme for people with disabilities is, in our opinion, paramount. An entitlement scheme would, for the first time, give Australian’s with a disability and their family’s security, peace of mind, an ability to plan and empower them to have more control over their lives.        

CSI asks the Commission to consider the following key issues in their deliberations.

•	Primary consideration should be given to the person’s preferred living arrangement.
•	Where practicable supports should be community based.
•	The NDIS should provide funding at a range of levels according to the person’s care needs and not based on funding caps.
•	The system should be easily accessible with easily identifiable points of entry.
•	Where possible there should be one assessment to avoid multiple assessments.
•	As people age the disability service system should be responsible for their ongoing support at an appropriate level.
•	The quality of services should be consistent, regardless of the funding source, with the use of one overarching quality assessment process.  
•	New models of service should be developed in response to changing community and consumer requirements.
•	Facilitation of the continuum of care is seen as a necessary activity in caring for, or supporting, anyone accessing a community service. It should not be identified as another service type. 
•	Consumers should be provided with choice through linkages across residential and community streams. 
•	There should be scope for sharing resources across community and residential arenas to enhance the quality of life and care outcomes for the consumer.
•	Special needs groups require innovative flexible models of care including, people with multiple disabilities, Indigenous people, those from diverse cultural and linguistic backgrounds, and those living in rural and remote areas.
•	There should be scope for sharing resources across community and residential arenas to enhance the quality of life and care outcomes for the consumer. 
•	The workforce is one of the keys to quality care and service, and staff must be well trained and supported. However, consumers should have input to training programs to ensure that the training reflects consumer expectations.
•	Consideration must be given to the timeframe of the transition. There are many clients who are still on a waiting list for services and or equipment. These clients must not get caught up in a bureaucratic time warp while decisions are being made.
•	CSI asks that consideration be given to the name of the scheme. The National Disability Insurance Scheme resonates with people who are eligible for services under the National Injury Insurance scheme. People who have an acquired disability through a motor vehicle accident, or similar injury, fit into the insurance model. However for anyone else with a disability, the emphasis should be on an entitlement to support rather than the benefactor of insurance. Entitlement is more conducive to a rights base service and underpins the concept of citizenship more appropriately than an insurance scheme.  
	
Carer Support
•	Disability affects the whole family and therefore income support should recognise the unpaid contribution made by family members in providing support to PWD thus savings to the community from people fulfilling a caring role that would otherwise be fulfilled by the state
•	Family circumstances are critical and developing resilience and appropriate levels of support to families to undertake their caring role without having to carry the burden of replacing services is critical. Mums, dads and families need to be able to be in their typical family roles and have the additional supports needed to help with the person’s disability, rather than feel they must take on all of those roles and take up the slack that comes from the absence of appropriate supports.
	
Individualised Funding Approaches
•	The service system must be person-centred, tailoring supports around individual needs.  People need to have real choices about the supports they receive and how they receive them.
•	CSI supports the idea of each individual with a disability having control over their allocated funding to enable them to have choice and control over the supports that they require.
•	Funding needs to be adequate to enable individuals to access the services and supports they need
•	Individuals with a disability and their families require good information in order to make choices about support options, and the opportunity to build their capacity to understand what might be possible and to build the kinds of supports that do not currently exist.  
•	Providing people directly with funds will not ensure that the options that they want or need are available in the market.  This may be due to the fact that such demand has not been predicted, or that the workforce is not skilled or attuned to meeting this particular need, or are entrenched in more traditional approaches.
•	Funding is not necessarily the solution to a good life in the community so there also needs to be the capacity for the facilitation of informal supports and community links.  Facilitation requires skills and resources up front but can have long term benefits. 
•	Funding needs to be made available to build the capacity of services, generic community resources and people with disabilities and their families in order to generate new options that facilitate a good life in the community. 
•	Individuals may not have the desire or capacity to develop or manage their own support plans, and need choice about how active they are in the administrative aspects of the support they receive.  Options need to be available for people to choose individual funding or to choose to use a financial intermediary, or have services managed by a disability service provider or other organisation.
•	Some funding may be required to maintain small specialist services that require continuity of expertise (such as early intervention programs) where demand may vary over time
•	While individuals and families may be budget holders of services, government needs to support an innovative and robust service sector that provides a range of services for people to purchase that will meet their needs.
	
Governance
CSI agree with the recommendation that a NIS should be administered by the Commonwealth Government and States and Territories should contribute the appropriate amount to the scheme. This would help standardise the quality of service, improve accountability, be more equitable and reduce fragmentation.

Phillip Beddall
Chairman, Community Support Incorporated.