Jesuit Social Services welcomes the opportunity to contribute to the National Disability Insurance Agency’s (NDIA) external consultation on its National Disability Insurance Scheme (NDIS) Support Coordination Discussion Paper (August 2020).

We recognise the complexity of needs experienced by people with disability, the challenges of providing and coordinating services in a way that meets each person’s individual needs, and the individual and broader economic benefits of providing effective support coordination to NDIS participants.

In this submission, we provide a brief overview of Jesuit Social Services’ work before responding to the targeted questions outlined in the NDIS Support Coordination Discussion Paper.

Jesuit Social Services works with a small, but highly complex, cohort of people with mild/moderate intellectual or cognitive disability and other complex needs who often require long-term support to navigate the relevant service systems.

Our submission draws on our experience working with participants who are often eligible to receive a combination of federal and state government financial support packages, including NDIS, and whose involvement in the justice and broader service systems is associated with significant disruption and discontinuity in their service provision.

Jesuit Social Services highlights that the existing NDIS fixed pricing structure does not accommodate the specialist and highly qualified and skilled workforce required to effectively support the cohort of people that we work with. Further, our organisation can only make financially viable the provision of NDIS services to this cohort in combination with additional support funding and the provision of NDIS support coordination. We outline how conflicts of interest can be effectively overcome in this context.

Jesuit Social Services notes a pattern of unilateral decision-making by the NDIA in relation to the NDIS, with limited or no consultation with service providers, and subsequent announcement of significant changes to pricing structures with very tight implementation timelines, despite significant impacts on the financial viability of service providers. We emphasise the need for the NDIA to engage in ongoing consultation processes and fine-tuning of policy and funding decisions in relation to the NDIS, and to provide adequate lead times for NDIS service providers to adjust their service offerings following any changes in these areas.

We look forward to further engagement with the NDIA in regard to these matters.