In late 2015 the National Disability Insurance Agency released for consultation a blueprint detailing how it will manage information, linkage and capacity building (ILC) activities under the National Disability Insurance Scheme.
This is crucially important work. People with disability have the right to full and equal participation in their community, yet many still experience systemic disadvantage. VCOSS believes the disadvantage and discrimination people with disability experience is not created by their impairments, but by the physical and social environment in which they live.
ILC activities, therefore, aim to address this by building the capacity of individuals and mainstream services to increase access and inclusion of people with disability, their families and carers, and helping people access timely information and support.
VCOSS strongly supports the ILC objectives. However, there is a lack of detail on many elements of the ILC Commissioning Framework making it difficult to provide meaningful feedback on the consultation draft.
In addition, the NDIA has not articulated how the ILC policy framework will interact with other elements of the NDIS and mainstream services including the Early Childhood Early Intervention (ECEI) approach, Local Area Coordinators (LACs), mental health services and aged care.
The VCOSS submission to ILC Commissioning Framework makes four recommendations to the design and structure of the grants process, detailed below, to ensure the ILC component (i) meets the needs of all people with disability, (ii) provide a fair and robust grants process which supports local partnerships and collaboration; and (iii) recognises the unique value of the community sector in supporting people with disability, their families and carers.
① Co-design the ILC activities to meet the needs of all people with disability and ensure continuity of support
The NDIA should ensure the ILC delivers activities for all people with disability, including those most vulnerable and people living in rural and regional areas. To help achieve this, the NDIA should actively involve people with disability in the full design of commissioning framework. This should be representative of diverse groups of people with disability, their families and carers, including Aboriginal people, people from culturally and linguistically diverse (CALD) backgrounds, people from metropolitan, regional, rural and remote areas, and people with a diversity of disabilities. VCOSS also recommends that the additional costs and challenges of delivering ILC activities in rural and regional be recognised to help ensure adequate coverage across Victoria.
The rollout of the NDIS shifts state and federal responsibilities, creating uncertainty for the future of many existing state-funded ILC-type initiatives such as the RuralAccess, MetroAccess and Deafaccess workers funded as part of the Disability Services Community Building Program. So people with disability, their families and carers do not lose essential services or there are gaps created in the transition to the NDIS, state and federal governments should clarify how the ILC framework will affect currently funded services and supports, including whether services will continue or be rolled into the ILC.
② Make the ILC outcomes framework clear, achievable and measurable
The NDIA should refine the proposed outcomes and measures so they are clear, achievable, measurable and represent the interests of people with disability, their families and carers. The framework would be enhanced by providing a program logic model that outlines how the outcomes framework will apply to individual organisations and the ILC framework as a whole. To accurately capture the impact of the ILC activities, its recommend that a range qualitative and quantitative data collection methods are used, with particular attention given to engaging vulnerable and hard-to-reach groups. Baseline data are also required to be able to measure and track the impact of the ILC activities.
The community sector, particularly small organisations, require support from the NDIA to move towards outcomes based performance measurement. This includes providing clear and timely information about the outcomes framework in advance of the ILC grant rounds opening, support to develop their practice to achieve outcomes, and ongoing training and guidance about how to capture and report on outcomes once the ILC activities are being delivered. The NDIA could also consider tasking an independent or semi-independent organisation with responsibility for supporting organisations, developing reporting measures for ILC activities and collecting high-level data.
③ Provide a fair and robust grants process
Small organisations have considerable local knowledge and expertise but need support to be successful in a competitive grants process. Larger organisations are often more experienced in tender processes and hold greater capacity to prepare sophisticated tender applications, giving them a competitive advantage. To help address this, the NDIA could provide training or workshops to support community sector organisations to apply for grants. This would be complemented by including criteria in the grants process for small community- based organisations who are well connected to their communities, or consider having a separate funding stream for small organisations.
Timely and clear (jargon free) information needs to be provided to the sector to support organisations plan and prepare for the ILC competitive grants process. Longer lead times also allow organisations to consider consortia or partnership arrangements. The application process should be commensurate with the size of the grants so that small grants do not have heavy administrative burdens. VCOSS also recommends developing robust funding criteria to ensure that ILC activities meet the needs of people with disability, families and/or carers and that organisations demonstrate local knowledge of the communities in which the ILC activities will be delivered.
The recent Senate reviews into the Department of Social Service (DSS) and Indigenous Advancement Strategy (IAS) competitive tendering processes which found both processes reflected fundamentally similar problems including: a lack of consultation; rushed processes with poor transparency; cutting the number of funding areas created significant challenges as organisations had to refocus their applications; uncertainty for providers, and negative impacts on smaller organisations. This resulted gaps in service delivery. The lessons learned from these tendering processes should be taken into account.
④ Expand the scope of social capital building activities
The ILC Commissioning Framework takes a relatively narrow view of social capital, focusing predominately on the role of volunteers. Supporting a broader range of actions that build social capital will deliver better outcomes for people with disability. For example, VCOSS members highlight the value that ILC recipients and people with disability could bring to building social capital. The community sector also works on a daily basis to build social capital, connect people to their community, and break down social isolation.
VCOSS recognise that volunteers play a crucial role in supporting people with disability to fully participate socially and economically in their communities and reducing barriers for in participation in community life. To be effective volunteers need to be adequately supported and linked to opportunities that align with their skills. There are substantial costs involved in doing this and community service organisations that work with volunteers need to be resourced to recruit, manage, train and develop volunteers, as well as to support the organisations that receive volunteers.
 The term ‘Aboriginal’ is used in this submission to refer to both Aboriginal and Torres Strait Islander peoples.
 The term ‘carers’ includes the diverse range of people in care relationships, including carers and people receiving care in same-sex families, ‘families of choice’, friends and others who provide unpaid care.
Banner image: Flickr/EasyStand (CC BY-NC-ND 2.0)