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L.I.S.A Inc
LISA... is a parent support and lobby group, for parents and families with a family member having an intellectual or multiple disability, and living in a supported accommodation group home in the State of Victoria, Australia.
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NDIS Funded State Public Service

 “A National Approach, or More of the Same!”

Victorian Entities moving towards State Dominance of Services under NDIS!

Current systems differ between states and territories, but the NDIS quality and safeguarding framework aims to be consistent across the country.

Moreover, existing arrangements for quality and safeguarding are based on funding agreements between governments and providers of support.

Our extensive evidence, over many years, shows the Department of Health and Human Services (DHHS) in Victoria, has been unable to ensure its direct care service delivery consistently equals its very extensive and very comprehensive service intent. 

If this state government department becomes a service provider throughout Victoria, we are at a loss to understand how it will consistently adhere to the NDIS Act and  the National Quality and Safeguarding Framework (NQSF).         

Attending the NDIS, NQSF seminar in Melbourne recently, ratified the absolute need NOT to allow existing state government and pseudo government departments/services to be part of, or associated with the NDIS.

Staff of the Office of the Public Advocate, Victoria, attended this event in force, making a very strong voice for maintaining such state entities within their existing, secure and well remunerated bureaucratic positions within the NDIS to continue their aversive power over vulnerable people and their families.  

This is in total contrast to the NDIS key factor of choice and control by the consumer - The NDIS, by contrast with such state funded services, funds individual participants who make choices about their own supports. 

The original intention of the NDIS being, (a) to reduce the waiting list for services and, (b) improve  service, accessibility, quality and accountability to the consumer.  Put the person with disabilities and their stakeholders in the driving seat, in contrast to state government bureaucrats driving consumers.   

This creates the need for a new quality and safeguarding framework whereby people with disabilities and their stakeholders will/should, within this framework  make, or be the key part of making judgments and decisions about the quality of providers, rather than the bureaucrats of such organisations as the Department of Health & Human Services, the Office of the Public Advocate or the Office of the Disability Services Commissioner.

The national quality and safeguarding framework has been shaped by principles such as choice and control, where the NDIS maximizes opportunities for people with disability to make decisions about their supports.  Whereas, the current bureaucratic processes in Victoria are in total control of the person with disabilities and their stakeholders.

Presumption of capacity — the NDIS should presume that all people with disability have the capacity to make decisions and exercise choice and control.  Unlike the current bureaucratic processes in Victoria, recognising when the person with disabilities does not have the capacity, and readily accept their stakeholders.

Supporting people to build natural safeguards:

  • Ensure service delivery consistently equals service intent.
  • Ensure service providers are not consistently in denial and avoidance of consumer scrutiny.  With the consumer treated as ‘always right’ rather than always wrong and, having a service entitlement. This is not how it will be if DHHS in Victoria is one’s direct care service provider!

National consistency — the quality and safeguarding framework should provide the same protection to people regardless of where they live in Australia.

Reducing/minimising regulation — the quality and safeguarding framework should create the least burden possible on individuals and providers of supports while still achieving the agreed quality and safeguarding aims of the framework.

Various elements will come together to form the quality and safeguards framework for the NDIS. In the consultation paper these elements have been grouped under three domains: developmental, preventative and corrective.

The NDIA also has a role in developing individuals' natural safeguards through its Local Area Coordinators (LACs), who help people with disability connect to providers, including providers of mainstream supports such as community and health services.

The NDIS service model is very different from former arrangements in most states and territories or in the Australian Government.  So long as it is totally different to that of the DHHS, Victoria!

In the NDIS, the most important relationship will be between participants and providers.

The capacity and intention of providers to deliver safe, high quality supports is therefore a critical safeguard.

A quality provider will usually have strong governance, policies and procedures and a corporate culture that fosters respect and openness.

Monitoring and Oversight.

Most important!


Complaints must be seen as tools to service improvement!

A complaints body must cover both systemic and individual complaints from consumers.

A complaints body must be a body of people not associated with government, pseudo government or the disability field.  The body should comprise of management people from various marketplace industries, independent of the disability field.  Such industries will provide ‘managers’ pro-bono, as a community service.  And, they are soon able to learn the ropes, yet be totally independent when evaluating complaints

Community Visitors:

Should there be community visitors (CVs) similar to those in Victoria?  Yes, but not with the current restrictive factors and watering down now being imposed by the OPA on the initial concept. 

  • The service evaluation of consumers (the person with disabilities and their stakeholder/s) must be included in the CV service evaluation reports.
  • Consumers must be permitted to meet with the CVs who evaluate their service.  Persons with disabilities must always be permitted to be represented by their stakeholder.
  • The current OPA/CV system does not allow either of the above .

Questionable practices by those associated with the present state disability services - practices which may adversely impact services under the NDIS when the scheme goes statewide. 

Almost all the current state disability services are totally controlled by the Department of Health and Human Services within their extensive and comprehensive care policies, standards, guidelines and values, and with the support of the Office of the Public Advocate (OPA), the Disability Service Commissioner and the Victorian Ombudsman.

With all the above mentioned government and pseudo government departments not wishing to lose influence, and employees their well-paid positions, to that of the NDIS - well demonstrated by the OPA in force at the NDIS seminar on the ‘National Quality and Safeguarding Framework (NQSF)’ in Melbourne recently, we cannot envisage the said state organisations disbanding or scrapping their influential and well entrenched policies and practices to the ‘NQSF’(national standards, policies and practice), and being under the direction of the NDIA when the NDIS goes fully national within the ‘National Disability Insurance Scheme Act 2013, rather than the Disability Act 2006,

Section 4(9) of the ‘National Disability Insurance Scheme Act 2013 enshrines ‘Choices and Control’ in the lives of those entitled to services under this Act.  Whereas, our extensive findings and well documented evidence illustrates quite the reverse for many receiving direct care services from the ‘Department of Health & Human Services (DHHS)’. 

Therefore, we are at a loss to understand the DHHS being accepted by the NDIA as an intended service provider across the state of Victoria. 

This state government department is currently a direct care service provider of its group homes in the Barwon Region within a proven track-record for which we have extensive documented evidence of the department being unable to consistently, properly and proactively manage their direct care services to ensure there are no disconnections between service intent and service delivery – a problem highlighted by the Victorian Auditor General in his report entitled ‘Accommodation for People with a Disability’, March 2008.

Most current residents of group homes throughout Victoria will see no other benefit from the NDIS, other than the right to move. 

They are currently restricted from moving by the DHHS Disability Support Register - a despotic procedure which controls the movement of all group home residents throughout the state. 

In contrast to CSOs under NDIS, the DHHS as a service provider under the NDIS will have the benefit of access to its state government funding sources to stay viable in what is intended to be a competitive marketplace - in contrast to the current and well established captive market.

Established group homes (residents) on transition to the NDIS, will see the state government’s block support service funding stop - replaced by ISPs from the NDIS.  DHHS direct care staff will see little more than a transparent change of funding, and will carry on as usual…  If the service was poor, it will remain poor!   

The Productivity Commission’s only answer to this was/is, “If a resident or their stakeholder does not like the service being provided, the resident is now free, and has the financial ability to move”. 

Whereas, (a) most people with high support needs do not move easily, (b)  there is unlikely to be much service choice in the near future, (c) The DHHS residential charge is much lower than CSO’s can allow within the overall funding they receive from the DHHS and, (c) the DHHS promote themselves to people with a disability and their stakeholders as having a far more secure tenure than CSOs, as they have the backing of the state government.  This is not equal opportunity in the marketplace!

The following is a new concept in the DHHS Residential Statement. A movement toward their intent to be a dominant service provider under the NDIS.  This ‘sales pitch’ includes support to be provided, and mention of the staff duty roster.  Normally the inference is that consumers should feel lucky and grateful for whatever they might get, and the staff roster is guarded from consumers like the crown jewels. 

New DHHS (Pre: NDIS) Group Home Residential Statement (extract)

Rostered staff provide person centred active support to residents in their daily activities such as personal care routines, preparation for day activities, meal preparation, managing money, travel, communication, support to manage health and wellbeing, community participation and inclusion. A roster is available in the group home identifying staff and the shift hours. Rosters are reviewed regularly and updated to reflect resident need. Rosters usually include overnight support such as sleepover or active night models.

Support will be based on the information provided to us in relation to your day to day support requirements, your goals and aspirations as outlined in your support plan (when developed) and be governed by any other planning that may be required.  Our staff will work with you to provide options and experiences that reflect your goals and needs. (LISA Comment – Link)

In Summary:  This all translates into little more, than more of the same supported accommodation under NDIS.  Yet the original intention of the NDIS was, (a) to reduce the waiting list for services and, (b) encourage better service provision with the service consumer, rather than the service provider in the driving seat.

Extra 1:  Mornington Peninsula, Victoria - DHS House of Horrors &
State Government Cover-ups     

Extra 2:  Bureaucratic Barriers Obdurate - The Age, by Max Jackson,
                April 21, 2015

Extra 3:  Captive-Market to Marketplace with NDIS

Extra 4:  A Safeguarding Framework for the NDIS by JacksonRyan
                Partmers - May 2015

Extra 5:  What does good support look like?
                 Beyond Qualifications and pay-rates
riffith University NDIS Symposium

Extra 6:  News Items

Extra 7:  Review of Victoria’s Charter of Human Rights

Government Funded Hypocrisy – “Governments fund services for people with disabilities. : They then fund advocates to keep the services honest : Then, they protect the services from the advocates”

Tel:  03-9434-3810:
Email: or

NOTE:  We are always interested in feedback and information; general, specific, good or bad.  If you wish anonymously: Our mail address is, 73 Nepean Street, Watsonia, 3087

LISA Inc   ~   Phone: 03 9434 3810   ~   Email:   ~   Address: 73 Nepean Street Watsonia VIC 3087

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