Executive summary
VMIAC is concerned that the proposed New Framework Planning and NDIS Supports changes could leave people with psychosocial disability with insufficient funding or unable to purchase the assistance they need. Simpler planning and greater flexibility could benefit consumers, but only if assessment accurately recognises their needs and funding is sufficient to meet them.
Assessment needs to account for fluctuating and less visible needs, including the assistance that enables a person to maintain stability. Consumers’ own accounts should carry substantive weight, with independent advocacy and peer support available throughout the process. Assessed needs should translate into sufficient funding, with clear explanations and effective ways to correct shortfalls. Disability support should never be conditional on accepting clinical treatment or following clinical advice.
The supports rules should preserve access to assistance that enables personal recovery and everyday participation, including peer support. Changes should protect consumers’ choice of effective supports and continuity of established assistance. VMIAC does not endorse reforms that prioritise cost containment over necessary support or shift responsibility to unpaid carers and systems unable to meet consumers’ needs. The complete rules and budget method should be published for further consultation, and their suitability demonstrated before rollout. Consumers should be involved throughout implementation, with effective review rights and independent monitoring that leads to action when problems arise.
Recommendations
- Publish the complete framework for further consultation
Publish the complete rules and budget method, with worked examples reflecting psychosocial support needs, and allow sufficient time for consumers and consumer-led organisations to influence the final approach. - Demonstrate that assessment accurately captures psychosocial support needs
Publish validation evidence for the modified I-CAN tool and broader assessment process, including testing with people who have fluctuating needs or multiple disabilities. Develop a dedicated psychosocial assessment module through co-design with consumers and consumer-led organisations. Assessment should consider needs over time and identify unmet needs, including assistance the person does not currently receive. It should distinguish what a person achieves with support from what they can sustain without it. - Protect treatment choice and consumer authority
Ensure access to assessment, assessment outcomes, and funding are never conditional on engaging with clinical treatment, taking medication, or following clinical advice. Recognise consumers’ accounts as substantive evidence, and do not obtain or rely on clinical records without their informed consent. Consumers’ own will and preferences should guide assessment and planning, including where a nominee, guardian, or administrator is involved. - Provide accessible assessment and funded assistance
Fund independent advocacy and peer support before, during, and after assessment, including throughout review processes. Ensure assessors understand psychosocial disability and include people with lived experience in the assessor workforce and in designing and delivering training. Provide culturally safe and accessible assessment options. Assessments should not occur during an inpatient admission or periods of acute distress unless the consumer chooses. People subject to compulsory treatment should not be disadvantaged in assessment or planning. - Make assessment and funding decisions transparent and open to correction
Provide assessment reports in accessible formats, with sufficient time and assistance to correct errors before plan approval. Explain how assessed needs translate into budgets and provide effective review rights. Participants should be able to correct funding shortfalls without repeating an accurate assessment. - Prevent inappropriate reliance on informal support
Base informal support offsets on what supporters can realistically and willingly provide, with the participant’s agreement. Funding should protect consumers’ autonomy and never leave them dependent on unsafe relationships, including where family violence is present. It should enable participants to leave those relationships. - Preserve access to appropriate psychosocial supports
Explicitly recognise psychosocial recovery support, peer support, practical tenancy assistance, and support to establish and sustain social connections within the support categories. Clarify funding responsibilities so overlapping needs do not leave participants without assistance. - Retain appropriate purchasing options and provide reliable advice
Retain a pathway to fund mainstream products that meet disability-related needs and publish the evidence and rationale for exclusions. Provide consistent, accessible purchasing advice and protect participants from repayment demands where they reasonably relied on official advice. - Respond promptly to changing needs and maintain continuity
Establish an urgent plan variation pathway and flexible funding periods that accommodate episodic needs. Maintain necessary support during reviews, reassessments, hospital admissions, and transition, including while an assessment is being replaced. Transition arrangements should prevent abrupt withdrawal of established assistance. - Make implementation conditional on readiness and ongoing accountability
Delay rollout until testing demonstrates that the framework can meet psychosocial support needs. Fund independent monitoring, with consumers and consumer-led organisations involved in evaluating outcomes and shaping corrective action. Public reporting should address unmet needs and cost shifting, with a clear process to pause or amend practices that cause harm.