The scope and audience of the Framework

The Framework covers NDIS supports and services delivered to participants. However, the NDIS covers only part of a broader disability sector, with around 4.4 million people in Australia (in 2019) estimated to have a disability (AIHW 2022). Additionally, over 2 million people with disability (in 2016) are estimated to have experienced forms of violence and abuse, as well as experiencing this violence at a much higher rate than people without disability (ABS 2021).

At the time of its development, some criticised the Framework for only applying to participants and NDIS funded supports, and not addressing issues of quality and safeguards in disability services more widely.

The Framework also noted that people who are not eligible for the NDIS should have access to community-based supports, which were envisioned to be available through the Information, Linkages and Capacity Building program. The purpose of the program included strengthening mainstream services, fostering improvement in disability support, minimising the escalation of issues and building individual capacity.

In Australia, there are numerous, sometimes overlapping, standards and frameworks for quality and safeguarding that affect people with disability more broadly than the NDIS, including for mental health, other disability services outside the NDIS and mainstream services. The Joint Standing Committee on the NDIS (2021) inquiry into the NDIS Quality and Safeguards Commission also noted that people with disability are confused by who does what, and where to go to complain about a service.

A range of priorities and actions to promote the safeguards and rights of people with disability are also set out in Australia’s Disability Strategy 2021-2031 and the supporting Safety Targeted Action Plan. These provide relevant considerations, including the interactions between the NDIS and other service systems.

We have heard and identified:

• Having different approaches to quality and safeguards for NDIS supports versus those provided through other systems leads to inconsistent standards of quality and safeguards for people with disability, as well as confusion. All services should be delivered in a consistent, safe and high quality manner, across all service systems.
• Limited investment has been made in improving the experience of participants accessing mainstream services, as part of the Information, Linkages and Capacity Building program, which creates gaps and inconsistencies when participants are accessing multiple different services.
• The aims and initiatives of the Framework are intended to support participants, as well as providers and workers. However, the Framework is a lengthy document that is inaccessible to participants, and potentially lacks impact with actors in the NDIS quality and safeguarding system.