Submission to the Department of Social Services consultation on Foundational Supports – General Supports
5 December 2024
Governments are working together to design and deliver additional supports in the community.
Foundational supports are specific supports that would be available outside the National Disability Insurance Scheme (NDIS) to help people with disability, and their families and carers.
PWDA provided the below submission to the government as part of consultations that were open to the public from 20 September 2024 – 5 December 2024.
Approaching Foundational Supports
In order to be successful and applicable to people with disability, General Supports need to be developed in a way that involves genuine and ongoing codesign and leadership by people with disability, at all stages of the consultation and development process.
These supports must be developed and implemented in such a way that demonstrates Australia's commitment to compliance with the Convention on the Rights of Persons with Disabilities (CRPD), recognising the real barriers we face in enacting and fully promoting the rights of all Australians with disability.
The submission looks at how foundational supports development requires:
- Genuine Co-design is crucial
- Further clarity is needed on Foundational Supports
Implementing Foundational Supports
Through PWDA's engagement on Foundational Supports there were specific calls for disability centric and inclusive services that cater to diverse needs, particularly multiply marginalised cohorts including First Nations, LGBTQIA+, CaLD, as well as regionally and remote located people of all age groups with disability.
It is recognised that these cohorts face additional barriers to accessing support and that the supports that currently exist are not equitable in terms of access, with many regions having little to no supports available.
Our submission also looked at;
- Accessibility of services and supports within Foundational Supports
- Improving existing (and future) disability supports within Foundational Supports
- What should General Supports look like?
- The need to rebuild trust - concerns about Foundational Supports
- Consultation Concerns
Impact and Systemic Considerations
PWDA stresses the importance of developing Foundational Supports through comprehensive co-design and co-development with people with disability and their representative organisations.
- Reduction of Impacts during Implementation
- Maintaining the integrity and essence of the NDIS
Recommendation 1: The co-design, development and implementation of Foundational Supports must actively include an ongoing commitment for leadership in co-design by people with disability and their representative organisations.
Recommendation 2: Collaboratively- led community education on the scope, roles and purpose of General Foundational Supports is needed to facilitate greater comprehension and understanding of these supports for the disability community.
Recommendation 3: All definitions and service design of General Foundational Supports must be co-designed and co-produced with people with disability and their representative organisations.
Recommendation 4: PWDA calls for Foundational Supports to be developed to directly meet the needs of multiply marginalised cohorts including First Nations, LGBTQIA+ and CaLD communities, with a strong focus on the regional and remote support gap and the needs of all age groups with disability. Supports must be culturally inclusive and trauma-informed, with equitable access across all states and territories.
Recommendation 5: Governments must provision for tailoring of Foundational Supports to meet the diverse, interacting and often overlapping needs of people with disability, resisting a one-size-fits-all or individual disability type only approach. PWDA believes this is best achieved through active collaboration and leadership by people with disability and their representative organisations.
Recommendation 6– Information services and supports within General Foundational Supports must be provided in a range of accessible and inclusive formats that support the diverse accessibility needs of Australians with disability, that recognises the different locations and ways people with disability access information and supports.
Recommendation 7: The Australian Federal, State, and Territory governments must work directly with people with disability and their representative organisations (state or territory peaks as well as national peaks) to develop and implement a nationally led, streamlined approach to Foundational Supports. This approach should require/regulate the need for consistency, equity, and access for all people with disability, effectively addressing the risks of a "location lottery" in service provision.
Recommendation 8: Clear rules regarding eligibility for accessing Foundational Supports, along with a well-defined, reduced threshold scope of what these supports encompass, are essential to avoid confusion, inequity, and unnecessary bureaucratic barriers. This will ensure that all people with disability can have their support needs met, either through Foundational Supports or by accessing services and supports within the NDIS.
Recommendation 9: PWDA advocates that a "no-wrong door" approach is taken. With all government agency staff and service providers, receiving comprehensive and compulsory disability affirming and led training on disability rights, relevant eligibility criteria, and the range and scope of supports available to ensure that staff and providers have a thorough understanding of how the system is interacted with and can provide accurate and accessible information to people with disability.
Recommendation 10: PWDA advocates that all government agency staff providing generalised information or supports must be trained in person-centred and trauma informed practice to meet the diverse needs of the disability community.
Recommendation 11: General supports must be designed to empower and resource advocacy and representative organisations to assist participants in navigating the system and to identify misinformation and gaps within government services and respond to systemic issues as they arise.
Recommendation 12: PWDA advocates that information, and services are provided in a way that is truly accessible, person-centred, flexible, consistent and inclusive. With independent and disability led review, development, and design of services by people with disability and their representative organisations.
Recommendation 13: PWDA strongly advocates for the use of consistent, accessible and simplified language/meaning across government services and departments, including NDIS and Foundational Supports. Language usage must avoid ableist and unnecessary jargon and consider the needs of all marginalized groups of people with disability.
Recommendation 14: All levels of government need to focus on strategies that will ensure equitable access to Foundational Supports, including through social media, across all regions and demographics to build trust and confidence in the Foundational Supports system. Ensuring that other legislation is not brought in that inherently impacts specific and vulnerable cohorts of people with disability.
Recommendation 15: Governments must utilise co-design and targeted strategies to build trust and confidence in the Foundational Supports System.
Recommendation 16: PWDA feels there is an urgent need for all levels of government to focus on strategies that ensure equitable access across different regions and demographics if they are to build trust and confidence in the Foundational Supports system.
Recommendation 17: PWDA calls for a consistent definition and usage of the term capacity building across government systems and programs including Foundational Supports and the NDIS/NDIA.
Recommendation 18: The development and implementation of General Supports needs to value local communities and informal supports and acknowledge fully the broad range of social and cultural backgrounds that Australians with disability are part of, and how these communities can support capacity building.
Recommendation 19: Foundational Supports should have embedded within its framework a nationally consistent approach to supported decision-making framework that upholds Article 12 of the CRPD and is consistent across all the states and territories.
Recommendation 20: Foundational Supports should be developed in close consultation with people with disability and their representatives and should emphasise supports that privilege a peer-led and disability-led approach
Recommendation 21: Any disability-led and peer-led practices within Foundational Supports must appropriately compensate people with disability for their skills and services in an equal capacity to other service providers.
Recommendation: 22 Federal and State and Territory Governments need to establish and maintain nationally consistent and equitable approaches to developing and implementing Foundational Supports that acknowledge the diverse cultural and geographical landscape across Australia
Recommendation: 23 Governments at all levels need to reestablish the trust of people with disability by listening and responding to their concerns and by having people with disability and their representative organisations play a central and ongoing role in the development and implementation of Foundational Supports.
Recommendation 24: PWDA feels it is imperative that no changes are made to NDIS participants plans or funding until Foundational Supports are fully implemented nationally.
Recommendation 25: Clear, low barrier and well-defined guidelines for eligibility and Foundational Supports scope is essential, reducing confusion, bureaucratic hurdles, and inequities.
Recommendation 26: People with disability must be consulted, and engaged in designing the policies and processes that will impact on them as the foremost experts and beneficiaries within the development of Foundational Supports.
Recommendation 27: Disability Representative Organisations and advocates must be centrally involved and consulted with, alongside and on behalf of people with disability, throughout all development and implementation of Foundational Supports including both General Supports and Targeted Supports.
Recommendation 28- The government must commit to maintaining current NDIS supports access until Foundational Supports are fully developed, trailed, and implemented consistently across all jurisdictions, confirmed by a nationally consistent set of standards evaluated by people with disability as effective. Therefore, any unsupported transition linked with the legislative changes to NDIS must be deferred to reduce direct quality and safety risks for people with disability.
Recommendation 29- Critical services currently provided and maintained through the NDIS to ensure the dignity, human rights, and autonomy of people with disability. This will preserve the core NDIS principles of choice, control, and independence, and prevent dilution of service quality.
Recommendation 30- Implementation of Foundational Supports must not replace or reduce services currently provided by the NDIS. Ensuring that current NDIS participants continue to receive the high-quality, person-centred services they require.
