VCOSS Submission to the NDIS Thin Markets Project

Thin markets in the NDIS – where there is a lack of appropriate services to meet the needs of participants – are of significant concern to VCOSS, our members, people with disability, advocates and the broader community. This includes where there are no services available, or where services that are available do not enable people with disability to exercise their choice and control.

Participants’ access to services, and choice over which services they engage, is a fundamental tenet of the NDIS. However, the emergence of thin markets means this is not realised for many people. VCOSS’ position is that people should have access to the services they need and choose regardless of where they live or the complexity of their needs, and providers should be able to deliver high quality services without operating at a loss.

VCOSS and our members strongly reinforce the need for greater intervention in, and stewardship of, NDIS markets, in contrast to the more ‘hands off’ approach that has been taken to date. Our submission to this project also reflects the significant amount of research, discussion and recommendations that have been made by others around NDIS thin markets in recent years.

 

 

Recommendations

 

• That the NDIA and Australian, state and territory governments take a more active approach to market stewardship.

• That NDIA and government roles and responsibilities are urgently clarified regarding market stewardship and the delivery of services for people with disability.

• That the NDIA begins to trial alternative commissioning models in 2019.

• That the NDIA and Australian, state and territory governments work together to deliver appropriate provider of last resort arrangements as a matter of urgency.

• That the NDIA provides greater access to NDIS market data and releases more information about its relevant work.

• That the next NDIS pricing review takes the real costs of delivering high quality services into account.

• That the NDIA undertakes a review of its approach to support coordination.

• That Australian, state and territory governments provide support and additional funding to maintain a strong disability advocacy sector.

 

 

 

Towards disability markets that enable access and equity

 

The role of the NDIA: from regulation to stewardship

Recommendations

• That the NDIA and Australian, state and territory governments take a more active approach to market stewardship.
• That NDIA and government roles and responsibilities are clarified regarding market stewardship and the delivery of services for people with disability.

Because service markets often fail, as we have seen with other attempts to marketise services – such as the Victorian vocational education and training sector[1] – market stewardship is needed. Market stewardship involves “oversight actions of government that fully support the functioning of public service markets,” in contrast to market regulation, which involves a “‘light’ touch approach”.[2]

In the past, services for people with disability were directly funded by governments based on historical funding formulas and a rationed service system. Through this approach, service gaps meant that the needs of people with disability were not met effectively. The transition to the NDIS, with a market constrained by prices, has led to the emergence of thin markets.

The importance of market stewardship in the NDIS has long been acknowledged across the sector[3] – including by the NDIA itself.[4] The original NDIS Market Approach paper, released in 2016, notes that “the Agency expects to play a more active role” in the market during the transition period.[5] With transition and early implementation of the NDIS continuing across the country, and with thin markets evident in many areas, VCOSS believes that recent approaches from the NDIA lean too heavily towards regulation and ‘enablement’ of the market,[6] rather than its active stewardship.

A recent report from the Australian Senate’s Joint Standing Committee on the NDIS finds similarly, that “as market steward, the NDIA should take a proactive role and put in place strategies and intervention mechanisms to address the significant risk of market failure in some areas and for some groups. The thin markets identified are not new; it is now urgent that the NDIA intervene beyond making small adjustments to pricing.”[7] Key areas in which VCOSS recommends increased intervention are outlined throughout this submission.

During consultations with our members the call for more active stewardship was strongly supported, with members expressly noting they do not support a light touch approach to addressing thin markets in the NDIS. This will mean greater strategic intervention to improve the delivery of services in thin markets, and must also include clearer structure and greater transparency around the “roles, responsibilities and activities of all those responsible for market stewardship.”[8]

Market stewardship must go beyond ensuring minimum protections and efficient use of resources and extend to ensuring that public good is fairly distributed.[9]

Lack of clarity around the roles and responsibilities of the NDIA and government jurisdictions has led to significant challenges for service delivery, the development of markets, and especially for individuals seeking disability and other supports.[10] VCOSS members point to the provision of appropriate and accessible supports for people experiencing mental illness as an area of particular concern across the state; this finding is supported by research from the Joint Standing Committee[11] as well as the recent establishment of a Victorian Royal Commission into the area.[12] Greater clarity will assist accountability around the NDIS, as governments, agencies and the community will know who is responsible for implementation of various elements, including market stewardship.[13]

Additionally, in order to meet its duties as market steward, the NDIA will require greater resources and increased capacity, including lifting the staffing cap.[14] The recent appointment of a dedicated federal Minister for the NDIS[15] is a positive sign that the Australian Government recognises the significance of the Scheme and its impact on the lives of people with disability and on service systems – VCOSS hopes that this will translate into changes for the NDIA’s focus on, and capacity to deliver, active stewardship, including increased staff numbers.

 

Trial new commissioning models to address service gaps

Recommendation

• That the NDIA begins to trial alternative commissioning models in 2019.

As a market-based system, the NDIS depends on a viable level of supply and demand for adequate service coverage and provider diversity, but this approach is currently not meeting many participants’ needs, and it risks entrenching and exacerbating social and health inequities.[16]

An evaluation of the NDIS last year found many participants have trouble accessing funded disability supports, primarily due to “small numbers or low capacity of service providers in local areas, lengthy waiting lists for some providers or types of support, and inflexibility of support hours.”^[17] If participants do not access funded services, even if this is because they are not available, they risk losing funding because planners are using this as evidence the supports are not required.^[18]

For people living in regional and rural Victoria or those with complex needs, there are often limited service options – in many cases there are not enough local services to provide people with their funded supports, let alone choice of providers. In these cases, participants must travel to services, pay extra for service staff to travel,[19] or miss out on services entirely.[20]

Additionally, a pure market approach to the NDIS – without active market stewardship – risks creating disincentives to supporting participants with complex needs or those perceived as ‘difficult’, such as people displaying challenging behaviour.[21] The Productivity Commission recognised this risk, noting that people with complex, specialised or high intensity needs, very challenging behaviours, or an acute and immediate need, are at risk of service shortages and poorer participant outcomes due to thin markets.[22]

VCOSS shares the views of many across the sector that that the NDIA should begin trialling alternative commissioning models to address service gaps caused by thin markets as soon as possible.[23] There are a range of forms this could take, including multi-faceted approaches, to ensure interventions are responsive to specific markets and their respective challenges and opportunities.

As the market steward, the NDIA has responsibility to develop a funding model for continued provision of disability services in areas of thin markets, including in rural and remote areas.[24]

For example, in 2017 the Joint Standing Committee recommended the NDIA develop a strategy to increase technology use in delivering services to rural and remote areas. Despite agreement from government and acknowledgement that this is “a key focus of the market stewardship and market intervention work,” as at March 2019 there was limited evidence that initiatives in this space have been developed or implemented.[25]

Models from other sectors could also be trialled for disability services, such as the Multipurpose Service model currently used in the aged care sector[26] and capital grants for housing or long-term subsidies like those provided by the National Rental Affordability Scheme.[27] Seed funding to encourage providers to move into new areas of service delivery could also be explored.[28]

 

Ensure there are appropriate providers of last resort

Recommendation

• That the NDIA and Australian, state and territory governments work together to deliver appropriate provider of last resort arrangements as a matter of urgency.

The ‘provider of last resort’ function in the disability sector has traditionally been undertaken by state governments, but with the implementation of the NDIS the responsibility for this role has become unclear and disputed.[29] As with most examples of thin markets in the NDIS, it is participants who bear the cost of this – with many documented cases of people experiencing significantly negative outcomes.[30]

While the Productivity Commission and the Joint Standing Committee have recommended that the NDIA clarify its Provider of Last Resort policy as a matter of urgency,[31] there has been limited progress to date and there is little accountability in this area. As noted by the Office of the Public Advocate, “the NDIA has reframed the concept of Provider of Last Resort as ‘critical support’ arrangements”[32] and has been piloting a project titled ‘Maintaining Critical Supports.’[33] However there is limited public information available on the project and its outcomes,[34] and it has not yet been extended across the country.

VCOSS and our members strongly recommend that appropriate provider of last resort arrangements be clarified and implemented as soon as possible. We support the Office of the Public Advocate’s recommendation that “the NDIA should publish, consult on and implement…[this] policy and framework as a matter of urgency.”[35]

Appropriate provider of last resort arrangements must be agreed by Australian, state and territory governments and the NDIA, and included in bilateral agreements and operational plans.[36] As part of these arrangements, contingency funding should be available when crises arise for NDIS participants, and crisis and respite accommodation must be able to be secured at short notice.[37]

 

Provide transparent NDIS market information and data

Recommendation

• That the NDIA provides greater access to NDIS market data and releases more information about its relevant work.

A key recommendation from recent reviews and research around the NDIS is the need to provide greater public access to relevant information.[38] This includes sharing market data to enable a better understanding of where thin markets currently exist, as well as sharing more information about the implementation of the NDIS and the progress of various pilots and trials. The NDIA recognises the provision of information is an important function of its role as market steward and notes it is likely to be its “most frequent market intervention” as it is “critical to the functioning of markets”.[39]

Of particular relevance to this project is the sharing of information about progress against the NDIS Market Enablement Framework. The Framework was released in November 2018[40] but there has been little information about how it has been applied since then.[41] The Framework outlines a range of ways through which the NDIA provides information “to improve the NDIS marketplace”,[42] but the frequency of publication of these is varied and several types of information have not been updated for a number of years:

• Provider Finder – a list of registered providers as at 31 March 2019 is available on the NDIS website. NDIS participants can also access the Provider Finder tool to search and filter provider lists through the NDIS myplace portal.[43]
• Market Insights – these are intended to “offer concise information into specific submarkets.” To date one Market Insight was released in November 2017, regarding the Assistive Technology market.[44] The NDIA has indicated a Market Insight paper around Specialist Disability Accommodation will be released ‘soon’.[45]
• Market Position Statements (MPS) – these statements provide information about marketplaces (including demand and supply) at the state level and for select local markets. To date, one MPS has been released for each state and territory, excluding Western Australia.[46] The Victorian MPS covers the North East Melbourne Area and was released in April 2016.[47]
• Market Analytics – Quarterly Reports are released four times per year. The most recent report covers the period to 31 March 2019.[48]

There is some recent movement in a positive direction, for example, with the NDIS Demand Map being released earlier this year through the Department of Social Services’ Boosting the Local Care Workforce Program,[49] but this information can still be difficult to find and should be more widely available and promoted. Likewise there is limited information available about the outcomes of the Maintaining Critical Supports project.[50]

VCOSS members also stressed the need for more information about NDIS markets, including data at the local level, so specific thin markets can be identified. Members consider there is a significant opportunity for the NDIA to work with local governments to improve data collection and sharing. Local governments have historically played a significant role in the sector, and have an existing relevant workforce, with service providers and community members often still seeking information from them. Although they have a strong interest in identifying gaps in service provision in their communities, they report there is currently limited visibility about local contexts and the potential for collaboration is not being utilised.

The collection of appropriate and relevant data is also fundamental. A recent study emphasised the importance of comprehensive data collection about the NDIS, noting that “information sharing about market conditions is not possible if the data…is not being collected.”[51] Currently it is not clear where there are genuine information gaps and where information exists but is not being publicly shared. Greater resourcing should be provided to the NDIA to facilitate the collection of market data as this is essential to identifying and beginning to address thin markets.

 

Deliver funding to support high quality services

Recommendation

• That the next NDIS pricing review takes the real costs of delivering high quality services into account.

Limitations of the current approach to NDIS pricing are well documented,[52] and VCOSS members report that pricing is the biggest factor influencing organisations’ ability to operate in thin markets. Over half of providers recently surveyed are concerned they will not be able to provide services at current prices (63 per cent) or will have to reduce service quality (54 per cent).[53]

VCOSS supports the Joint Standing Committee’s recommendation that the next NDIS pricing review should better reflect the administration and professional development costs of operating in the NDIS environment.[54] Travel costs are also a considerable concern for VCOSS members operating in regional and rural Victoria, and it is strongly felt that the current approach does not adequately reflect the cost of providing rural services. Pricing changes through the 2019-20 NDIS Price Guide are welcome[55] – it is essential that prices “cover the real costs of service delivery to people with complex and challenging support needs.”[56]

Organisations report that the level of red tape involved with the NDIS can affect the viability of their service delivery.[57] For VCOSS members, the importance of ‘red tape’ that is used to protect service quality and safety is well understood, and this is distinct from ‘bureaucratic processes’ that seem cumbersome without improving service delivery.

Adjusting NDIS pricing is considered by disability service providers to be the top priority to support robust service markets.[58] Our members also suggest greater engagement with the not-for-profit sector would be beneficial, to support provider diversity and community connection and improve the sector’s financial sustainability in the NDIS.

 

Fund support coordination

Recommendation

• That the NDIA undertakes a review of its approach to support coordination.

VCOSS members share the concerns of many across the sector about the importance of support coordination and the need for a more effective approach to its funding.[59] Support coordination is especially critical for people with complex needs.[60]

In 2018 the Joint Standing Committee recommended ensuring “support coordination is adequately funded in Plans to meet Participants’ needs and not limited to a fixed period,”[61] however little progress has been made in this respect.[62] As at 31 March 2019, support coordination was included in 40 per cent of active NDIS participants’ plans (and only 41 per cent of plans that had been approved through January to March 2019).[63]

Our members continue to emphasise the need for greater ongoing support to assist people in navigating the NDIS. While case management is not funded under the NDIS, advocates and organisations maintain this is an essential function to support people to engage with the NDIS and access the services and supports they require.[64] For example, the Victorian Government currently provides intensive support to individuals “experiencing significant issues in their NDIS transition,” working across the pre-planning, planning and post-planning stages.[65] This type of support is seen as critical by the sector, and governments and the NDIA should work together to ensure that ongoing case management can be provided to participants with complex and challenging support needs.[66]

We recommend the NDIA reviews its approach to support coordination to take into account feedback and recommendations provided by the sector to date. This includes assistance for support coordinators who are struggling to navigate thin markets and support people with complex needs,[67] and not limiting support coordination to a fixed period of time.[68]

 

Boost funding for independent disability advocacy

Recommendation

• That Australian, state and territory governments provide support and additional funding to maintain a strong disability advocacy sector.

Disability advocacy empowers people with disability, and their families and carers, to understand and communicate their human and legal rights, and have their needs met.[69] The importance of maintaining independent advocacy as the NDIS is implemented is acknowledged by the Productivity Commission.[70]

Independent disability advocacy can help people access and navigate the NDIS, articulate their needs and goals, and receive meaningful plans. Disability advocacy can also help people make a complaint or request a plan or decision review. It is particularly important for people with complex needs or facing disadvantage, or those with limited informal supports or networks.[71]

The NDIS has already had, and will continue to have, a significant impact on the workloads of disability advocates. For example, disability advocates located in the Barwon launch site reported that 90 per cent of their caseload was taken up with NDIS matters. While the organisation was receiving some Commonwealth funding through the External Merits Review Program, this did not allow them sufficient time to conduct other advocacy work.[72] Many Victorian disability advocacy organisations report that their waiting lists are currently closed due to overwhelming demand, and staff are under considerable stress.

The advocacy sector requires increased investment and funding certainty to enable them to respond to increased demand from the NDIS and continue working with people with disability who are not NDIS participants. Funding for advocacy also brings a return on investment to government,[73] a particularly important consideration for governments and the NDIA in terms of providing for the financial sustainability of the NDIS.

[1] Per Capita, Training Days: Models of Vocational Training Provision: Lessons from the Victorian Experience, July 2013.

[2] G Carey, H Dickinson, E Malbon and D Reeders, ‘The Vexed Question of Market Stewardship in the Public Sector: Examining Equity and the Social Contract through the Australian National Disability Insurance Scheme’, Social Policy & Administration, January 2018, vol.52, no.1.

[3] See, for example, the Productivity Commission’s National Disability Insurance Scheme (NDIS) Costs Study Report (October 2017) and the Joint Standing Committee on the National Disability Insurance Scheme’s reports into Transitional Arrangements for the NDIS (February 2018) and Market readiness for the provision of services under the NDIS (September 2018).

[4] See, for example, the NDIS Annual Report 2015-16:Towards an ordinary life, and the NDIS Market Approach: Statement of Opportunity and Intent (November 2016).

[5] NDIA, NDIS Market Approach: Statement of Opportunity and Intent, November 2016.

[6] See, for example, NDIA, National Disability Insurance Scheme Market Enablement Framework, October 2018.

[7] Joint Standing Committee on the National Disability Insurance Scheme, Market readiness for the provision of services under the NDIS, September 2018, p.73.

[8] Joint Standing Committee on the National Disability Insurance Scheme, Market readiness for provision of services under the NDIS, September 2018, p.ix.

[9] G Carey, E Malbon, A Marjolin and D Reeders, National disability markets: Market stewardship actions for the NDIS, Final report, Centre for Social Impact, October 2018, p.6.

[10] Victorian Office of the Public Advocate, The illusion of ‘Choice and Control’, September 2018.

[11] Joint Standing Committee on the National Disability Insurance Scheme, Provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition, August 2017; Joint Standing Committee on the National Disability Insurance Scheme, Progress Report, March 2019.

[12] Royal Commission into Victoria’s Mental Health System, 2019, https://rcvmhs.vic.gov.au/.

[13] Australian Auditor-General, National Disability Insurance Scheme – Management of the Transition of the Disability Services Market, ANAO Report No.24 2016-17, Performance Audit, Australian National Audit Office, 2016.

[14] G Carey, E Malbon, A Marjolin and D Reeders, National disability markets: Market stewardship actions for the NDIS, Final report, Centre for Social Impact, October 2018, p.6.

[15] H Belot and D Conifer, ‘Scott Morrison unveils new ministry as Coalition prepares for majority government,’ ABC News, 26 May 2019, https://www.abc.net.au/news/2019-05-26/election-2019-scott-morrison-unveils-government-ministry/11150626.

[16] G Carey, E Malbon, D Reeders, A Kavanagh and G Llewellyn, ‘Redressing or entrenching social and health inequalities through policy implementation? Examining personalised budgets through the Australian National Disability Insurance Scheme,’ International Journal for Equity in Health, 2017, vol.16, issue 192.

[17] K Mavromaras, M Moskos, S Mahuteau and L Isherwood, with A Goode, H Walton, L Smith, Z Wei and J Flavel, Evaluation of the NDIS: Final Report, National Institute of Labour Studies, Flinders University, February 2018, p.56.

[18] D Warr, H Dickinson, S Olney, J Hargrave, A Karanikolas, V Kasidis, G Katsikis, J Ozge, D Peters, J Wheeler and M Wilcox, Choice, Control and the NDIS: Service users’ perspectives on having choice and control in the new National Disability Insurance Scheme, University of Melbourne, 2017, p.8; A Aikman, ‘Fund cuts hit NDIS remote customers,’ The Australian, 22 March 2019, https://www.theaustralian.com.au/nation/health/ndis-fund-cuts-hit-remote-clientele/news-story/b3dee0070e5f2c6386d8ea7ce13d96e9.

[19] D Warr, H Dickinson, S Olney et al, Choice, Control and the NDIS: Service users’ perspectives on having choice and control in the new National Disability Insurance Scheme, University of Melbourne, 2017, p.8.

[20] A Aikman, ‘Fund cuts hit NDIS remote customers,’ The Australian, 22 March 2019, https://www.theaustralian.com.au/nation/health/ndis-fund-cuts-hit-remote-clientele/news-story/b3dee0070e5f2c6386d8ea7ce13d96e9.

[21] Victorian Office of the Public Advocate, The illusion of ‘Choice and Control’, September 2018.

[22] Productivity Commission, National Disability Insurance Scheme (NDIS) Costs, Position Paper, Canberra, 2017, p.227.

[23] Joint Standing Committee on the National Disability Insurance Scheme, Progress Report, March 2019, Recommendation 11, p.50.

[24] Ibid, p.50.

[25] Ibid, p.117.

[26] Joint Standing Committee on the National Disability Insurance Scheme, Market readiness for provision of services under the NDIS, September 2018, Recommendation 23, p.74; see also p.73.

[27] Australian Department of Social Services, National Rental Affordability Scheme – Frequently asked questions, webpage, 2018 (accessed 27 May 2019), https://www.dss.gov.au/housing-support/programs-services/housing/national-rental-affordability-scheme/national-rental-affordability-scheme-frequently-asked-questions. This is discussed in further depth in VCOSS’ 2018 submission, Choice, control and certainty in SDA: Submission to the Department of Social Services’ Review of the SDA Pricing and Payments Framework.

[28] National Disability Services, NDIS Market Dynamics Study, National Disability Services Victorian NDIS Sector Development Project, April 2019; G Carey, E Malbon, D Reeders, A Kavanagh and G Llewellyn, ‘Redressing or entrenching social and health inequalities through policy implementation? Examining personalised budgets through the Australian National Disability Insurance Scheme,’ International Journal for Equity in Health, 2017, vol.16, issue 192.

[29] Victorian Office of the Public Advocate, The illusion of ‘Choice and Control’, September 2018.

[30] Victorian Office of the Public Advocate, The illusion of ‘Choice and Control’, September 2018; Victoria Legal Aid, Submission to the Joint Standing Committee on the National Disability Insurance Scheme: Market Readiness, March 2018; Victoria Legal Aid, Submission to the inquiry into transitional arrangements for the NDIS and into general issues around the implementation and performance of the NDIS, November 2017.

[31] Joint Standing Committee on the NDIS, Market readiness for provision of services under the NDIS, September 2018, Recommendation 24, p.78; Productivity Commission, National Disability Insurance Scheme (NDIS) Costs, Study Report, October 2017, Recommendation 7.1, p.54.

[32] Victorian Office of the Public Advocate, The illusion of ‘Choice and Control’, September 2018, p.33.

[33] NDIA, From the CEO – March 2018, webpage, 2018 (accessed 27 May 2019), https://www.ndis.gov.au/news/ceo/ceo-march-2018.

[34] National Disability Services, NDIS Market Dynamics Study, National Disability Services Victorian NDIS Sector Development Project, April 2019.

[35] Victorian Office of the Public Advocate, The illusion of ‘Choice and Control’, September 2018, Recommendation 8, p.37.

[36] Joint Standing Committee on the NDIS, Transitional Arrangements for the NDIS, February 2018, Recommendation 9, p.35.

[37] Victorian Office of the Public Advocate, The illusion of ‘Choice and Control’, September 2018.

[38] G Carey, E Malbon, A Marjolin and D Reeders, National disability markets: Market stewardship actions for the NDIS, Final report, Centre for Social Impact, October 2018; Joint Standing Committee on the NDIS, Market readiness for the provision of services under the NDIS, September 2018; Victorian Office of the Public Advocate, The illusion of ‘Choice and Control’, September 2018.

[39] NDIA, National Disability Insurance Scheme Market Enablement Framework, October 2018, p.5.

[40] NDIA, From the CEO – November 2018, webpage, 2018 (accessed 29 May 2019), https://www.ndis.gov.au/news/ceo/ceo-november-2018.

[41] For example, the Market Enablement Framework is not mentioned in the latest NDIS Quarterly Report (Q3, 31 March 2019) or in any CEO Updates released in 2019.

[42] NDIA, National Disability Insurance Scheme Market Enablement Framework, October 2018, p.5.

[43] NDIA, Find a registered provider, webpage, 16 May 2019 (accessed 29 May 2019), https://www.ndis.gov.au/participants/working-providers/find-registered-provider#how-do-you-find-service-providers.

[44] NDIA, Market Insights: Assistive Technology, Issue 1, November 2017, https://www.ndis.gov.au/media/361/download.

[45] NDIA, Market Insights, webpage, 25 January 2019 (accessed 29 May 2019), https://www.ndis.gov.au/providers/market-information/market-insights.

[46] NDIA, Market position statements, webpage, 26 February 2019 (accessed 29 May 2019), https://www.ndis.gov.au/providers/market-information/market-position-statements.

[47] NDIA, Market Position Statement: Victoria – North East Melbourne Area, April 2016, https://www.ndis.gov.au/media/376/download.

[48] NDIA, Quarterly Reports, webpage, 3 May 2019 (accessed 29 May 2019), https://www.ndis.gov.au/about-us/publications/quarterly-reports.

[49] Australian Department of Social Services, Boosting the Local Care Workforce Program: NDIS Demand Map, webpage, 2019 (accessed 29 May 2019), https://blcw.dss.gov.au/ndis-demand-map/.

[50] National Disability Services, NDIS Market Dynamics Study, National Disability Services Victorian NDIS Sector Development Project, April 2019.

[51] G Carey, E Malbon, A Marjolin and D Reeders, National disability markets: Market stewardship actions for the NDIS, Final report, Centre for Social Impact, October 2018, p.2.

[52] National Disability Services, NDIS Market Dynamics Study, National Disability Services Victorian NDIS Sector Development Project, April 2019; Joint Standing Committee on the National Disability Insurance Scheme, Progress Report, March 2019; G Carey, E Malbon, A Marjolin and D Reeders, National disability markets: Market stewardship actions for the NDIS, Final report, Centre for Social Impact, October 2018; VCOSS, Submission to the Joint Standing Committee’s inquiry into transitional arrangements for the NDIS, August 2017.

[53] National Disability Services, NDIS Market Dynamics Study, National Disability Services Victorian NDIS Sector Development Project, April 2019, p.7.

[54] Joint Standing Committee on the National Disability Insurance Scheme, Progress Report, March 2019, Recommendation 16, p.58. This is discussed in further detail in VCOSS’ Submission to the Joint Standing Committee’s inquiry into transitional arrangements for the NDIS, August 2017.

[55] NDIA, NDIS Price Guide 2019-20, July 2019.

[56] Victorian Office of the Public Advocate, The illusion of ‘Choice and Control’, September 2018, pp.34-35.

[57] National Disability Services, NDIS Market Dynamics Study, National Disability Services Victorian NDIS Sector Development Project, April 2019.

[58] G Carey, M Weier, E Malbon, H Dickinson, D Alexander and G Duff, How is the disability sector faring? A report from National Disability Services’ Annual Market Survey, Centre for Social Impact, UNSW Sydney, p.9.

[59] Victorian Office of the Public Advocate, The illusion of ‘Choice and Control’, September 2018; Joint Standing Committee on the NDIS, Transitional Arrangements for the NDIS, February 2018, p.77.

[60] Ibid.

[61] Joint Standing Committee on the NDIS, Transitional Arrangements for the NDIS, February 2018, Recommendation 21, p.77.

[62] Joint Standing Committee on the National Disability Insurance Scheme, Progress Report, March 2019, p.102.

[63] NDIA, NDIS Quarterly Report Q3 2018-19, Report to the COAG Disability Reform Council, 31 March 2019, p.85.

[64] Victorian Office of the Public Advocate, The illusion of ‘Choice and Control’, September 2018.

[65] Victorian Department of Health and Human Services, National Disability Insurance Scheme (NDIS) – child and family system interface: Practice guidelines for Child FIRST, The Orange Door, Integrated Family Services, Child Protection and Out-of-Home Care, September 2018, p.44.

[66] Victorian Office of the Public Advocate, The illusion of ‘Choice and Control’, September 2018, Recommendation 11, p.37.

[67] Ibid, Recommendation 10, p.37.

[68] Joint Standing Committee on the NDIS, Transitional Arrangements for the NDIS, February 2018.

[69] Disability Advocacy Resource Unit, What is disability advocacy?, 2016, http://www.daru.org.au/wp/wp-content/uploads/2011/12/What-is-disability-advocacy_final-June-2016.pdf.

[70] Productivity Commission, Inquiry Report into Disability Care and Support, Volume 1, 2011, p.25.

[71] VCOSS, Submission to NDIS Joint Standing Committee inquiry into Transitional Arrangements for the NDIS, August 2017.

[72] Disability Advocacy Resource Unit, VCOSS and Disability Advocacy Victoria, Response to the Review of the National Disability Advocacy Framework discussion paper, July 2015.

[73] A Daly, G Barrett and R Williams, A Cost Benefit Analysis of Australian Independent Disability Advocacy Agencies, for the Disability Advocacy Network Australia, 2017.