Chapter 4Information, Linkages and Capacity Building
4.1This chapter provides background on the Australian Government's Information, Linkages and Capacity Building (ILC) program, and outlines the current structure and administration of the program. It discusses stakeholder views on the ILC program, drawing out central issues explored during the committee's inquiry.
4.2Overall, the committee heard strong support for the aims of the ILC program, with consensus that the program is vital to the efficacy and sustainability of the National Disability Insurance Scheme (NDIS). However, the committee consistently heard that the implementation of the ILC program has not achieved its aims due to issues with the program's funding design, administration, and lack of investment in the program.
Background
4.3The ILC program is a key component of the three-tiered system of NDIS supports originally recommended by the Productivity Commission in 2011. The ILC program was formerly known as 'Tier 2' of the NDIS, designed to be accessible to all Australians with disability, their families, and carers, irrespective of whether they had an NDIS plan. Each tier of the NDIS was intended to service a different target population, with the costs inversely related to the size of the target populations (Figure 4.1 below).
Tier 1 of the NDIS encompasses all Australians, as the NDIS 'provides insurance against the costs of support in the event that they acquire a significant disability' and 'seek[s] to minimise the impacts of disability for all Australians';
Tier 2 of the NDIS is for all people with a disability, and their families and carers, to access information, referral, and other disability services; and
Tier 3 of the NDIS is for people with disability who require funded, individualised supports through participant plans.
Figure 4.1The NDIS is part of a broader system of supportsa
Source: Productivity Commission, National Disability Insurance Scheme (NDIS) Costs Study Report, October2017, p. 4.
4.4The NDIS was never intended to be an 'oasis in the desert' with supports only available to those eligible for an NDIS plan. The ILC program is critical to this, benefiting both those who require individualised NDIS participant plans and those requiring less intensive support. The 'very important role' that the ILC program plays within the broader framework of the NDIS was explained in the ILC Investment Strategy:
While an individual's NDIS plan lies at the core of the Scheme, the way a participant interacts with family, friends and the community, mainstream services, and NDIS Partners in the Communities (including both Local Area Co-ordinators and the Early Childhood Early Intervention Partners), helps them engage socially and economically.
4.5In 2015, Tier 2 was renamed 'Information, Linkages and Capacity Building' to clarify its intended purpose: to connect people with disability, as well as their families and carers, to appropriate mainstream, community and informal supports and services; to build the capacity of individuals with disability to participate in the community; and to make communities more inclusive of and accessible to people with disability.
4.6The ILC program reflects one of the core insurance principles of the NDIS: investment in community participation and building social capital. This is intended to reduce the demand for, and level of support required through, funded individualised supports (Tier 3). The program has the potential to drive systemic change in societal attitudes and practices by seeking to 'promote the social and economic inclusion and meaningful participation of people with disability', which cannot be achieved through individualised supports alone.
The structure and administration of the ILC program
4.7The ILC program currently consists of two components:
(a)ILC grants, administered by the Department of Social Services (DSS), and
(b)referral, information, and capacity building services, undertaken by Local Area Coordinators (LACs) and overseen by the National Disability Insurance Agency (NDIA).
4.8Grants are the main component of the ILC program, and are divided into four funding streams:
(a)Individual Capacity Building – to enable access to peer support, mentoring and other skills building for people with disability, their families and carers;
(b)Mainstream Capacity Building – to improve the capacity of mainstream services to respond to and include people with disability, increasing accessibility and use of mainstream services;
(c)National Information Program – to provide relevant, up-to-date information on supports and services through consistent national information programs and products for people with disability, their families and carers; and
(d)Economic and Community Participation – to improve pathways to employment and increase participation by people with disability.
4.9In January 2021, administrative responsibility for ILC grants transferred from the NDIA to DSS, with the aim of better integrating and aligning the program with other national disability policies and programs, such as Australia's Disability Strategy 2021–2031. DSS considered that ILC grants were discrete from the operation of LACs, and that these processes could be 'separately administered without any adverse impacts on people with disability'.
4.10The DSS was of the view that LACs should continue to be administered by the NDIA, as LAC activities are 'linked to the NDIA's core function of administering the NDIS through plan development, and the LAC network is part of the NDIA's national footprint'.
4.11The committee notes the recommendations of the Disability Royal Commission may affect future governance arrangements for the ILC grants program.
4.12ILC grants complement the work of LACs, who are 'the local face of the ILC, connecting people with disability to their local community, services and programs'. LACs should have a good understanding of their local ecosystem of disability supports, so that they are able to assist people in accessing the services they need. The three main roles of LACs are:
(a)assisting NDIS participants to understand and implement their plans;
(b)connecting people with a disability who do not have a NDIS plan to mainstream and community services; and
(c)working with the local community to improve inclusion and accessibility for people with disability.
Views on the ILC program
4.13The committee heard a range of views on the ILC program throughout this and other inquiries. Many stakeholders supported the intent of the program and acknowledged the value it can provide, while criticising the way it has been administered and implemented in practice.
4.14The ILC program was described by various submitters as 'vital in fostering innovation within the scheme' and a 'crucial component of the various mechanisms to develop the NDIS'. The committee heard examples of numerous ILC-funded projects that had achieved positive outcomes for vulnerable groups of participants, such as people with disability from culturally and linguistically diverse backgrounds and young men with progressive neuromuscular disorders.
4.15The potential for ILC grants to significantly improve the participation of people with disability in the community was clearly articulated by the Save Our Sons Duchenne Foundation:
The grants delivered under this program are innovative, ground-breaking and of critical importance to ensuring people with disabilities are able to break through barriers and participate more fully in the social and community life of their community … These projects will invariably return a 'dividend' to the Government (and taxpayer) as the increased participation of people with a disability in employment, social and community life will more than offset any financial costs of the grants program.
4.16The committee also received evidence that the ILC program plays an important role for advocacy and volunteer organisations, with ILC grant recipients Autism Tasmania explaining:
It has enabled capacity building around autistic individuals, the broader community and ourselves as an organisation to keep contributing to that … We've been able to use ILC grant funding to develop our program of capacity building that takes people from autism right through to practiced development.
4.17JFA Purple Orange, a disability advocacy organisation, released a paper in June2023 explaining that the ILC program is critical to realising the transformative potential of the NDIS:
Without a framework for ILC-type initiatives, the NDIS will remain largely a 'transactional benefits' scheme, where participants buy conventional disability supports, services, and products, reinforcing a status of paid service recipiency. Instead, with a robust framework of ILC-type initiatives, the NDIS has a far better prospect of becoming a 'transformational benefits' scheme, where participants and other people living with disability are genuinely taking up valued membership in community life.
4.18However, stakeholders concurred that the ILC program has generally fallen short of its stated aims. JFA Purple Orange highlighted that the ILC program had received insufficient attention and investment, and called for the NDIS to 'return … to its original concept' which would involve appropriately funding and effectively implementing all three tiers of NDIS supports as envisaged by the Productivity Commission. Others raised various concerns with the ILC program, including issues with the funding design of ILC grants, administration of ILC grants by DSS, and the insufficiency of ILC services undertaken by LACs.
Funding design
4.19The committee heard substantial criticisms of the current funding design of ILC grants, with stakeholders querying the appropriateness of delivering the ILC program through a competitive grant model. Huntington's Australia explained that in practice, smaller organisations lacking the resources to dedicate to preparing grant applications may be unfairly excluded from ILC funding:
Due to the competitive nature of the ILC grant rounds, many worthy proposals do not get funded. In some senses, this approach potentially discriminates against smaller cohorts, or those with only or largely volunteer staffed organisations compared to better funded agencies or those who can afford to hire professional grant writers.
4.20A 2021 report by the Centre for Social Impact suggested that:
The competitive nature of a grants scheme is counter-productive to and disincentives collaboration and shared learning, stifles opportunities to expand the scale of change, and undermines organisational capacity and workforce retention.
4.21The ACT Government further recognised that ILC grants place an 'onerous administrative burden' on community organisations through the application and reporting requirements, while the Mental Illness Fellowship of Australia suggested that there was little incentive for organisations to apply for ILC grants due to the 'short funding period and small amounts available'.
4.22The short-term duration of many ILC grants was said to contradict the program's aims of individual and community capacity building, which require more secure, long-term investment. Without stable, ongoing services or community workers to turn to, people with disability, their families and carers are left uncertain about where and how they can access support. A representative from a disability peer support organisation described the grants as 'short-sighted' and leading to a 'situation where we're scrambling for funding all the time', which diminishes the ability of community organisations to build experience and expertise in delivering services.
4.23A Melbourne Disability Institute report on Tier 2 of the NDIS found 'there is limited opportunity for organisations to build on previous work, as activity ceases and organisational expertise is lost when dedicated funding ends'. The City of Newcastle pointed to the staff turnover that occurs in community organisations because of insecure ILC funding:
… many ILC programs … lack a level of security and this impacts their relationship building, staff retention and overall community outcomes. Turnover in staff in community service organisations, the use of volunteers at the community level and expectations of how inclusion might be delivered are not fully and effectively resourced by ILC grant funding.
4.24Similarly, the NPY Women's Council gave evidence that the short-term nature of ILC grants was not conducive to developing a local disability support workforce in remote Aboriginal and Torres Strait Islander communities:
Building peoples' capacity and capability to undertake disability support work requires gradual and well supported process. It entails structured training and long-term support and supervision, as well as a high degree of flexibility to cater for some of the cultural issues likely to arise.
4.25The NPY Women's Council highlighted the need for ILC funded projects in remote Aboriginal and Torres Strait Islander communities to be provided on a long term, ongoing basis in order to build trust with the community. This sentiment was echoed by the City of Newcastle, which made the point that rather than being a set and forget process to deliver inclusion, 'it is relationship based and this takes a longer term community development approach'.
4.26In addition, submitters emphasised that ILC grants were delivered on a 'piecemeal' basis and displayed little 'strategic intent or linkage with measurement of the overall benefits of the identification of gaps in the market'. Submitters claimed that ILC funded projects were inconsistently offered across different geographical regions without consideration of a broader strategy to effect systemic change. Autism Tasmania reflected on the difficulties linking state and federal services:
We have to work very hard to find out what's happening nationally and connect so that we can build on what we're doing locally and augment that with stronger outcomes in our community … there have been some significant misses because of that not incentivising people to collaborate and build on what's there.
4.27This was consistent with research conducted by the Melbourne Disability Institute which found that there was 'no overarching collection of data or assessment of collective impact' in relation to ILC grants.
4.28The committee heard various suggestions for improving the funding design of ILC grants. Submitters suggested that essential activities being provided by organisations with a strong track-record of effective service delivery should receive direct, recurrent funding without the need for a grant application. Where grant applications were required, Huntington's Australia suggested that providing advance notice of funding cycles would 'help level the playing field' by allowing smaller, less-resourced organisations more time to prepare grant applications.
4.29The committee heard numerous calls for the duration of ILC grants to be greater than twelve months to facilitate longer term, systemic change. In a similar vein, the Centre for Social Impact reported that a key theme in interviews and surveys it conducted in 2021 was that:
To achieve change, [ILC] funding predominantly needs to be longer term (three to five years). Longer term funding also recognises the extra time required to undertake co-design and to engage in work with some cohorts, for example people with intellectual disability, people whose first language is not English, people from culturally diverse backgrounds, and people in remote areas.
4.30The Centre for Social Impact further suggested that the aims of the ILC program would be better served by a funding design that was driven by a strategic view of current and future needs in order to 'focus investment on the necessary pieces of work' and seek out 'connections to address intersecting and interdependent issues'. For example, interviewees proposed that DSS actively invite tenders or expressions of interest from appropriate organisations to deliver services that align with an overarching strategy for ILC funding.
4.31Autism Tasmania highlighted the need for more robust methods for evaluating the ILC grant process, noting:
The ILC grants and the different themes didn't start with a common evaluative framework so that all of the different investments can be evaluated consistently and the reinvestment based on a solid foundation of data … there are risks of those investments being eroded and not built on.
4.32DSS reported in 2021 that in its ongoing review of the ILC program, it would investigate 'a range of options for future grants funding including commissioning, equitable and upfront jurisdictional split' and would 'consider the strategic intent of ILC now the NDIS has reached full scheme'.
Administration by DSS
4.33Stakeholders largely expressed dissatisfaction with DSS's administration of ILC grants, with some submitters suggesting that the administration of ILC grants be returned to the NDIA.
4.34The Save Our Sons Duchenne Foundation was alone in suggesting that the transfer of administrative responsibility for ILC grants to DSS had created 'more opportunities for integrated and coordinated service provision'. This echoed DSS's stated aim to 'ensure closer alignment with other disability services and initiatives, such as the National Disability Strategy, the National Disability Information Gateway and Disability Employment Services'.
4.35On the other hand, the South West Autism Network was concerned that the transfer of administrative responsibility to DSS had severed important connections between ILC providers and the NDIA:
Since the ILC program was transferred to DSS in 2020, there has been a loss of connection and information sharing between ILC providers and NDIA. Prior to the change, ILC providers were able to quickly contact their NDIA grant manager and discuss issues and concerns identified in the community. There was opportunity for feedback direct to NDIA, and to work with NDIA to address systemic issues at a local level. This connection has been lost to the detriment of both NDIS participants and how NDIS operates.
4.36In addition, MS Australia submitted:
This move is concerning, as it creates a clear bureaucratic partition and signalling to the community – between the 'haves' and the 'have nots'.
4.37Mr Andrew Vodic of the Community Disability Alliance Hunter similarly reported that ILC grant administration 'became a very hands-off bureaucratic process rather than a relationship with our funder'.
The role of local area coordinators (LACs)
4.38The committee frequently heard throughout a number of its inquiries that LACs have neglected their role in delivering referral, information and capacity building services. In its 2022 Report on the Current Scheme Implementation and Forecasting for the NDIS, the committee noted that:
Local area coordinators are … intended to assist with navigating community supports, but the committee has heard for a long time that these positions have largely been focused on planning rather than connecting to community supports through the earlier stages of the scheme.
4.39JFA Purple Orange explained that there is an inherent tension between the different duties that LACs are expected to perform. Connecting people with appropriate community services and supports 'requires a high degree of proactive intentionality, and time', whereas assisting NDIS participants to navigate the system is 'likely to include responding to urgent and unexpected situations'. It suggested that the latter duty is often prioritised over the former due to the urgent and high-pressure nature of the work.
4.40This tension was also observed by Allied Group:
It appears that LAC has become an extension of the NDIA functions with an emphasis on bureaucratic funding related activities such as planning (for funded supports) and plan reviews over other functions.
4.41Stakeholders underscored the difficulty of the LAC role, describing LACs as 'under the pump' and 'lacking the time or capacity' to undertake ILC activities.
4.42The committee heard evidence that difficulties engaging with LACs was reflective of wider staffing issues across the NDIS, with NOSS Tasmania explaining:
There appears to be a high turnover of NDIA staff and related staff, such as local area partners and coordinators of support … Our staff report often working with people who are just learning their roles and, therefore, are not as skilled or as knowledgeable.
4.43This was further reflected by Vincent Industries Inc, which gave evidence that a key issue for NDIA capability and culture was the 'high number of personnel changes in roles such as local areas coordinators and coordinators of support'.
4.44DSS reported in 2021 that in its ongoing review of the ILC program, it was working on the 'development of a new strategy … [to] understand the evolving role of LACs'.
The need for increased funding
4.45Submitters to multiple inquires roundly called for increased funding for the ILC program, pointing to the disconnect between the program's very broad aims and the relatively small amount of funding it receives.
4.46The Melbourne Disability Institute's 2022 research report into the 'Tier 2 tipping point' comprehensively argued for greater investment in the ILC program. In a submission to the committee's 2022 inquiry into Current Scheme Implementation and Forecasting for the NDIS, it argued:
With an expected number of NDIS participants of 533,000 and approximately 4 million people in Tier 2, it is self-evident that allocating such a small amount of money to all people with disability who are not eligible for the NDIS is grossly inadequate ($33 per person compared with the average package size of the NDIS of more than $70,000 per person).
4.47The submission further highlighted the importance of investing in the ILC program to ensure the sustainability and equity of the NDIS:
So long as there is a 'cliff' at the edge of the NDIS, rather than a gentle slope, the NDIS will not be sustainable or equitable. Increased support for those not eligible of the NDIS therefore needs to be addressed as a matter of urgency.
4.48Deaf Services agreed that funding for the ILC program was severely inadequate:
With such a large and broad remit, the funding is not adequate to deliver initiatives in any long-term and meaningful capacity given projects are short term and relatively small in scale.