Submission from the Australian Psychosocial Disability Collective (APDC) on Foundational Supports

Thank you for the opportunity to contribute to the consultation on General Foundational Supports.
The Australian Psychosocial Disability Collective (APDC) is a grassroots advocacy group made up of NDIS participants who experience severe and enduring mental illness. We advocate for individuals living with psychosocial disabilities.

Introduction

The APDC generally supports the introduction of funding for General Foundational Supports. Still, we have specific concerns regarding how these supports are being implemented, particularly concerning the mental health system and the NDIS. This submission focuses on the implications of Foundational Supports for people with psychosocial disabilities.

Understanding Psychosocial Disability

Psychosocial Disability is often misunderstood as a lesser form of disability. It is a severe and enduring condition that arises from mental ill-health and is compounded by social, economic, cultural, and environmental factors. People with psychosocial disability often experience co-occurring conditions and the impacts of trauma, stigma, and discrimination. These factors contribute to significant disadvantage, including poverty, housing instability, social isolation, and an increased incidence of suicide.

It is important to distinguish psychosocial disability from mental ill-health. While mental health challenges contribute to psychosocial disability, the latter encompasses a broader range of lived experiences, including significant impairments in various aspects of life, such as employment, education, relationships, social interactions, and self-care. Effective support should aim to improve or maintain functioning or, at the very least, slow the decline of an individual’s capabilities.

Concerns Regarding Foundational Supports

Foundational Supports are designed for people who do not meet the eligibility criteria for the NDIS, typically those with less severe and less permanent disabilities. Funding for these supports, as costed in the NDIS Review Report, is estimated to be below $6000 annually per person. However, this level of support will often be inadequate to address the complexities of psychosocial disability. There is a concern that Foundational Supports may increase fragmentation within the mental health system rather than provide a cohesive alternative. Current mental health services are already underfunded, fragmented, and overburdened, leaving many people without the support they need. While Foundational Supports will inject much-needed funding, they may fail to address the most urgent needs in the psychosocial disability community, particularly given the complex nature of the support required.

Addressing the Gaps in Support Services

The current mental health system is fragmented and difficult to navigate, with long waitlists and limited access to essential services. Foundational Supports must go beyond simply providing referrals to mainstream services, which are often inaccessible to people experiencing isolation and emotional distress. Instead, they should offer practical, accessible, community-based alternatives that are tailored to the needs of people with psychosocial disabilities.

Concerns About Eligibility and NDIS Access

One of the primary concerns with the introduction of Foundational Supports is the potential for people with psychosocial disabilities to be excluded from the NDIS and instead placed into these lower-level support programs. The recent trend of eligibility reassessments for existing NDIS participants has raised concerns that people with psychosocial disabilities may be removed from the scheme entirely. This is particularly troubling given the lack of clarity around how Foundational Supports will function alongside the NDIS and whether they will lead to reduced access to necessary supports.

Choice, Control, and Autonomy

Choice and control are fundamental principles in the NDIS. However, people with psychosocial disabilities must be assured that these principles will be upheld under the new Foundational Supports framework. The design of these supports must prioritize the autonomy of individuals, ensuring that they are not coerced into receiving inadequate or inappropriate services.

Early Intervention and Recovery Models

The introduction of an Early Intervention pathway for people with psychosocial disabilities raises questions about how this will interact with Foundational Supports. The new pathway could delay access to the NDIS or limit people’s ability to transition into the full NDIS system. Moreover, the emphasis on "recovery-based" models of support is problematic for people with severe and permanent disabilities, as recovery is not always achievable or realistic for many individuals. The focus should instead be on providing ongoing support that allows people to live fulfilling lives, even in the face of persistent disability.

The Social Model of Disability and Human Rights

Foundational Supports, as currently proposed, do not adequately address the growing demand for psychosocial disability services and may undermine the social model of disability that underpins the NDIS. By focusing on low-cost, temporary supports, there is a risk that these measures will violate the rights of people with disabilities, further entrenching social isolation and exclusion. The government must reconsider the trajectory of NDIS reforms to ensure they align with the principles of human rights and social justice.

Recommendations

The APDC urges the government to:

1. Reassess the eligibility criteria for Foundational Supports and ensure that people with psychosocial disabilities, regardless of the severity or permanence of their condition, can access appropriate support.

2. Integrate choice and control into the design of Foundational Supports, ensuring that individuals can access services that meet their unique needs.

3. Ensure that the NDIS remains accessible to people with psychosocial disabilities without forcing them into a lower level of support that is inadequate for their needs.

4. Promote peer support models and community-based initiatives that address social isolation and help individuals with psychosocial disabilities connect with others.

5. Develop better training and education for workers in the NDIS and Foundational Supports to ensure that services are delivered in a way that respects the lived experience of people with psychosocial disabilities.

Additional Points

• Foundational Supports should be linked to early intervention pathways.
• Digital-only supports, such as online self-advocacy, will not meet the needs of all individuals.
• Rural communities should not be forced to rely on service providers that have previously caused trauma.
• More clarity is needed on the dividing line between Foundational Supports and access to the NDIS.
• There is a need for increased service capacity, as many current services are already overwhelmed.

The APDC calls for a more inclusive, supportive, and rights-based approach to designing and implementing Foundational Supports and NDIS 2.0.

Conclusion

Communication about the purpose and structure of Foundational Supports has been inadequate, with limited consultation and insufficient information provided to the disability community. To truly uphold the rights and dignity of people with psychosocial disabilities, the government must engage in meaningful, co-designed consultations that reflect the complexities of psychosocial disability.
The APDC advocates for reforms that prioritize inclusion, support, and empowerment for individuals with psychosocial disabilities, in line with the original vision of the NDIS.