VALID Bulletin on NDIS


SFF Submission to Joint Standing Committee on the NDIS

SFF President’s Email to the Joint Standing Committee on the NDIS with the submission.


I am writing to you as President of Supportive Families and Friends Association Inc. (SFF)  a volunteer-led support association in Victoria for families with a family member living in disability accommodation.

The majority of our members are drawn from the families of about 2500 residents living in about 450 group homes (the Transfer homes) which were managed by the Victorian Department of Health and Human Services (DHHS) until their management recently transferred to one of five non-government providers selected following a request for expressions of interest. The Victorian Government has retained ownership of most properties and continues to employ staff in the homes under secondment arrangements. It must be noted that residents had no choice in these changes which were imposed on them. The Victorian Government introduced this change concurrently with the rollout of the NDIS.

I am writing to ask the Committee to give urgent consideration to this very vulnerable group of residents and their families. All of the residents are considered by the NDIA to have complex needs.

Each of the residents now has an NDIS Plan, but the largest item, SIL, is zero , as the Transfer homes continue to be funded by the Victorian Government under in-kind arrangements. This group of residents do not yet receive SIL funding from the NDIS.

I have attached the SFF submission to the recent NDIS Consultation on Supported Independent Living (SIL). The Context section of our submission sets out in some detail the state of transition for this particular group of residents and their families. I will highlight a few key points:

Until the Transfer of the homes, the residents lived in a very stable environment, in which the Victorian Government had a “Duty of Care” for the residents. This was implemented through the DHHS,  which reported through the Minister to the Victorian Parliament. As the  Victorian Government progressively withdraws from its role in  the management of the group homes, Duty of Care becomes blurred.

The residents now live in a very confusing and complex environment. The roles of the SDA and the SIL are now split between two different providers, yet residents do not currently have a service agreement with either. The single Residential Agreement that a resident had with the DHHS will ultimately be replaced by many agreements. Residents will be expected to negotiate agreements with the NDIA, SDA and SIL providers, a day Service, a Support Coordinator, a Plan Manager, a Behaviour Support Plan provider, and various allied health providers. A daunting task!

It is generally accepted that NDIS participants who benefit most from the Scheme are those who can self-advocate or have someone to advocate for them. As explained in our attached submission, most residents that we support do not fit into either of these categories. This group of residents will not receive the support from the NDIS that they should unless they receive independent advocacy. The Victorian Government provided limited funding for independent advocacy for some residents in their initial Plan meetings, but we have been informed that the money has been spent.  Independent advocacy is not available. It is not appropriate for Support Coordinators or SIL Providers to be de facto advocates, as they often do.

SIL changes are being introduced as group homes in Melbourne are currently in crisis. Day services have been closed since March and residents have been at home 24/7 for months. Their routines have been severely disrupted. The residents are at a high-risk of catching the coronavirus, as mask wearing, good hygiene and social distancing are difficult to implement. Many residents have not seen their family in months, and have no social contacts outside their home. The sector has lost hundreds of its most experienced support workers under a Victorian Government Early Retirement Scheme. The departed staff have generally been replaced by less experienced casual staff, leaving hundreds of unfilled permanent staff vacancies. It is not possible to conduct face-to-face meetings.

As NDIS Plans of these residents come up for review, residents and their families are being thrust into the world of SIL funding, at a time that  it appears to be in a state of confusion. NDIS documentation stresses the need for residents and their families to be consulted in the preparation of the individual Roster of Care (ROC), yet many of our members report to us that this is not happening. The NDIS has developed a NDIS SIL Participant Information Pack, which can be found on its website, but it is not sent to participants.

The NDIA does not appear to acknowledge that participants (residents in this case) with a cognitive impairment, or other severe disabilities, have a much greater need for support than do participants who are not in this category.  SIL funding must not be on a “one size fits all” basis, it should take into account the greater support needs of participants with a cognitive Impairment or other severe disability.

The existing arrangements do not give families confidence that the NDIS will provide their family member with the  “reasonable and necessary” supports that they need to enjoy a satisfying life!


Phil Lipshut


Supportive Families and Friends association Inc.

0438 948 994,au

SFF Submission NDIA on SIL

Supported Independent Living Information Pack from NDIS

Your provider will ask you or your nominee to sign a form saying you agree with the roster of care. Your
planner will also check you are happy with your roster of care during your planning meeting. Who has seen their ROC?