Leading our Own Supports: Response to the Department of Social Services Consultation Paper on Category C: Service for One/Self Directed Support Registration
7 February 2025
In December 2023, the Independent Review of the National Disability Insurance Scheme (NDIS Review) recommended the government develop a system for registration of NDIS providers and workers.
In February 2024, the government established the NDIS Provider and Worker Registration Taskforce (the Taskforce) to provide expert advice on how to make the system work fairly for participants and providers.
Following widespread community concern about the recommendation that all NDIS providers be registered, PWDA welcomed the Taskforce recommendation that participants can continue to use unregistered supports by registering themselves with the NDIS Quality and Safeguards Commission (the NDIS Commission) under a separate ‘Service for One/Self-Directed Support Registration’ category.
Self-directed supports is a significant step forward in enabling NDIS participants to exercise greater choice, control, and independence over their lives.
While some oversight by the NDIS Commission is needed, it is important that the rules don’t make things too difficult for participants and providers to follow. We need simpler processes and enough resources for managing the tasks so everyone can participate.
Building skills for participants and providers is important. Training, support from peers, and sharing knowledge will help people gain the skills and confidence to handle their own supports. This should also include formal protections to make sure that people can make their own choices without being taken advantage of or harmed.
The NDIS Commission needs to find a balance between protecting participants and respecting their independence. Safety measures should support, not weaken, participants’ natural supports and choices. A rights-based approach that builds participants’ confidence and resilience will follow the principles of dignity and inclusion in the CRPD.
Recommendations
Recommendation 1: The model of Self-Directed Supports Registration should be different from the Self-Management of NDIS plans.
Recommendation 2: The NDIS Commission needs to find a balance between protecting participants and respecting their independence.
Recommendation 3: Make sure that registration process is simple, quick, and easy for participants and their representatives to manage. The processes should be simple for everyone to use, including those who have little support.
Recommendation 4: Section 10 NDIS Inclusion list should change to include costs that might be needed like bookkeeping or accounting software and be funded through participants’ NDIS plans.
Recommendation 5: The registration portal must be fully accessible and co-designed with people with disability to meets the needs of all participants. It should also work with existing NDIS online systems.
Recommendation 6: The NDIS Commission must create a reporting and complaints system for providers, separate to the participant-employer dynamic. This is to handle issues like workplace safety and employment violations, while also protecting the integrity of participants’ self-directed supports.
Recommendation 7: Members of multiple marginalised communities such as First Nations or from rural, regional and remote areas often have added difficulty accessing the documentation and technology required for reporting. The government and NDIS Commission should create special arrangements for these individuals based on their situations and work with those communities to co-design supports that are culturally appropriate.
Recommendation 8: The NDIS Commission should make it easier for providers in rural areas to meet compliance rules. To prevent losing important services and ensure people still get the support they need.
Recommendation 9: The NDIS Commission should provide simple guidance on what participants can do if quality and safety measures fail. This should include practical steps and clear pathways for addressing issues.
Recommendation 10: The NDIS Commission should establish processes to identify self- directed participants who may be at risk of financial abuse or coercion, including situations involving family members or carers. These processes should include pausing compliance obligations and providing referrals to specialist domestic and family violence services or other relevant supports to ensure participants’ safety and autonomy are upheld.
Recommendation 11: Provide simple instructions on what is required by participants and providers. Develop practical tools and resources to support participants and providers to understand and meet requirements.
Recommendation 12: To prevent issues with current supports, the NDIS Commission should make the registration for self-directed supports simple and quick. Refusing or taking away registration should only happen after trying every possible way to help the participant.
Recommendation13: When requesting information for a decision or review the NDIS Commission must allow a minimum of 90 days to respond, in line with existing NDIS policies.
Recommendation 14: That the NDIS Commission design and plan the timing and format of check-ins with Self-Directed participants to be flexible, accommodating for participants’ preferences, support and accessibility needs.
Recommendation 15: Schedule check-ins at regular intervals, such as every 3 or 12 months, to avoid surprises and help participants plan and prepare.
Recommendation 16: Check that participants natural support systems (e.g. connections with family, friends, and community) are working to protect them from violence, abuse and neglect and how well they know their rights. The NDIS Commission should provide help to strengthen these supports, like community activities and training in self-advocacy and decision-making.
Recommendation 17: Recognising that certain types of supports, such as intimate personal care and 24/7 support, increase risk to participants, the NDIS Commission should check-in with self-directed participants on the type of supports they are receiving and how long they are being provided.
Recommendation 18: Set clear processes to find out who decides a participant’s support during check-ins. This is to make sure their rights and choices are respected and reduce substitute decision-making based on CRPD principles.
Recommendation 19: To ensure participants are not stopped from making their own decisions, clear steps should be made to find out who decides on a participant’s supports during check-ins.
Recommendation 20: Following the Disability Royal Commission’s advice, the NDIA should change nominee rules to support decision-making and ensure that choices made by a participant’s chosen decision-maker match the participant’s wishes and preferences.
Recommendation 21: The government should, through the implementation of Foundational Supports, provide training and resources that support the family, carers and kin of people with disability to empower people with disability to self-advocate and make their own decisions.
Recommendation 22: Provide programs that foster peer support and knowledge-sharing among participants to ensure participants have the skills they need. Programs should be designed to use the skills and knowledge of participants who self-direct their supports, and let them share experiences and develop innovative, scalable solutions for meeting support needs.
Recommendation 23: Establish information hubs and communities of practice (COPs) to allow people to get and provide support and knowledge between peers. They must be accessible, flexible, and inclusive, allowing for different communication and learning styles. Online hubs, discussion forums, and COPs should provide participants with templates, best practice examples, and a safe, moderated space to connect and share.
Recommendation 24: Information hubs and COPs should specifically address the needs of multiple marginalised groups, such as First Nations, transgender, women, and gender-diverse individuals with disabilities. This could for example include providing support and funding for community led yarning circles for First Nations participants and gender-specific peer support groups for women and gender-diverse individuals.
Recommendation 25: Work closely with people with disability and organisations to co-design the rules for registration of self-directed supports. Consider the potential that registration of self- directed supports might exclude some groups of participants and / or limit support options for individuals.
Recommendation 26: Ensure registration works with other proposed NDIS reforms, particularly mandatory registration for providers of certain types of supports.
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