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WIRU Community Health & Well-Being Pty Ltd

Submission to the Support Coordination Reform Consultation

Guiding people. Connecting systems. Creating better outcomes.

About WIRU

Specialist navigation led by professional accredited Social Workers

WIRU Community Health & Well-Being is an independent, Social Worker-led registered NDIS provider specialising in specialist support coordination and navigation. We work with participants whose needs sit across disability, justice, mental health, housing, health and community systems, including people transitioning from custody, hospital or forensic mental health settings.

We intentionally operate as a navigation-only service. We do not provide accommodation, support work or therapy, which helps preserve independence and reduces conflict of interest when assisting participants to build the right support arrangements.

This submission also sought cultural consultation from WIRU's First Nations Cultural Consultant, reflecting the importance of cultural safety, local knowledge and respectful engagement when considering future SCC design, especially in justice and remote contexts.

Who we support

Participants with complex and overlapping needs, including justice involvement, psychosocial disability, cognitive impairment, safeguarding concerns and thin market challenges.

How we work

Small caseloads, multidisciplinary coordination, supported decision-making, professional boundaries and continuity of trusted relationships.

Where we work

South Australia and Queensland, with experience in metropolitan, regional and remote settings and across multiple government interfaces.

Why this matters

The future SCC model should not unintentionally remove small specialist providers whose expertise and independence are critical for high-complexity participants.

Specialist navigation across complex systems

For participants with overlapping needs, coordination often means holding multiple systems together at the same time.

PARTICIPANT WIRU SPECIALIST NAVIGATION independent • conflict-free • relationship-based JJusticecustody • correctionsrelease planningstatutory interfaces HHealthhospital • mental healthclinical teams • discharge HOHousingSIL • tenancy • transitionsprovider readiness • stability GGuardianshipconsent • decision-makingsafeguardingrepresentatives NNDISplans • budgets • providersimplementation • review CCommunityfamily • culturelocal servicesbelonging • continuity APBS & allied healthOT • behaviour supportpsychology • assessment

The value of specialist coordination is often in the connections between systems, especially where responsibilities overlap or service gaps emerge.

WIRU overall position

  • Commissioning should improve consistency and safeguarding without reducing access to independent specialist providers.
  • Participants with justice involvement, forensic histories or multiple system interfaces require specialist coordination capability - not a generic high-caseload service.
  • Regional and remote arrangements must recognise thin markets, travel, cultural safety and the need to work across service boundaries.

Part 1 - What participants should receive from the future SCC service

The full participant-focused responses from WIRU's written submission.

The most effective part of the current model is continuity: participants can build a trusted relationship with a coordinator who understands their goals, risks, communication needs and service history. For complex participants, good coordination is not merely referral activity. It often involves active work across several systems.

  • working alongside hospitals, mental health teams and allied health practitioners
  • coordinating release or discharge planning from custody, forensic mental health or hospital settings
  • liaising with guardians, substitute decision-makers and statutory agencies
  • bringing providers and government agencies together when responsibilities overlap or break down

The future model should more clearly distinguish between general connection support and genuinely specialist coordination. Participants with straightforward needs do not require the same intensity, workforce capability or safeguarding response as people leaving prison, leaving secure care, or navigating cognitive disability, psychosocial disability and homelessness at the same time.

The mode of service should be determined by participant need, not provider convenience. Virtual engagement can work well for case conferences, short follow-up and some regional coordination. Face-to-face support remains essential where trust-building, supported decision-making, risk management or cultural engagement are central.

  • Face-to-face should remain available for participants with significant cognitive or communication needs, psychosocial disability, trauma, low digital access, or complex transitions.
  • Virtual options should complement, not replace, relationship-based specialist practice.

Specialist SCC capability is particularly important for people experiencing several issues at once: disability, justice involvement, unstable housing, behavioural complexity, safeguarding concerns, hospital discharge, cultural barriers or limited decision-making supports.

  • This includes people transitioning from prison or forensic mental health settings into the community.
  • It also includes participants in thin markets who cannot simply be referred to readily available local services.

For participants with higher and more complex needs, SCC workers require more than general disability-sector experience. They need demonstrated practice capability in disability, risk and safeguarding, supported decision-making, trauma-informed practice, psychosocial and cognitive disability, professional documentation, and working across mainstream and statutory systems.

  • WIRU supports stronger minimum workforce expectations for specialist coordination roles, including relevant tertiary qualifications, professional supervision, ethical accountability and, where applicable, registration or accreditation with a recognised professional body.
  • In specialist and high-complexity practice, qualifications such as Social Work, together with professional accountability through bodies such as the Australian Association of Social Workers (AASW), should be recognised as important indicators of workforce capability.
  • Lived experience and cultural knowledge remain highly valuable, but they should complement - rather than replace - the professional knowledge, supervision and accountability required when workers are coordinating complex risk, safeguarding and cross-government responsibilities.
  • The future SCC model provides an opportunity to strengthen workforce standards in an area where formal qualification requirements and professional oversight have historically been limited.

Participants should know who their worker is, what the organisation can and cannot do, how information is used, how to make a complaint safely, and that the coordinator does not have a financial interest in directing them toward particular supports. Conflict-free practice is an important safeguard.

The design should avoid assuming that bigger organisations are automatically safer or more effective. Small specialist services can deliver very high-quality coordination because they keep caseloads manageable, maintain senior oversight, and develop expertise in a clearly defined participant cohort.

Part 2 - Service provider models and approaches

The full provider-model responses from WIRU's written submission.

WIRU supports a model that allows multiple provider types within a region, including specialist providers. A structure that appoints only one or a very small number of large regional providers risks reducing choice and removing specialist capability.

  • Regional arrangements should leave room for small specialist providers, Aboriginal Community Controlled Organisations, culturally specific services and niche providers working with high-complexity participants.
  • Participants with specialist needs should be able to access a specialist SCC provider even where that organisation is not the primary regional lead.

Lead organisations should be assessed on governance, safeguarding, workforce capability, local relationships, cultural responsiveness, professional supervision, conflict management and demonstrated outcomes - not merely scale.

  • Where a lead organisation also provides accommodation, direct support or therapy, it should be required to demonstrate strong conflict-of-interest controls.

A lead model may support consistency and infrastructure, but it also risks favouring large organisations with tendering capacity over providers with the strongest specialist practice. Any lead model should include clear pathways for specialist subcontracting, referral or direct commissioning.

Regions should not be defined solely by administrative convenience. Participants move between metro, regional, hospital, prison and community settings. Coordination should be able to follow the participant across those contexts, and specialist providers should be able to work across regional boundaries where that reflects the participant journey.

Caseload expectations must reflect complexity. A simple numeric caseload target would be inappropriate. Some participants need light-touch navigation. Others require sustained coordination during critical periods such as prison release, hospital discharge, housing breakdown or safeguarding incidents.

  • Small caseloads should be recognised as a legitimate quality and safeguarding strategy, not a weakness.

Funding should recognise the real work involved in high-quality coordination: participant engagement, interagency case conferences, travel, clinical liaison, risk management, documentation, escalation and transition planning. Payment settings should not reward volume at the expense of quality.

WIRU supports strong minimum requirements including worker screening, supervision, cultural capability, documented safeguarding systems, complaint handling, information governance, conflict management and clear evidence that workforce capability matches the participant cohort.

Specialist practice in prisons, justice and forensic settings

  • Participants leaving custody, secure care or forensic mental health settings often require intensive coordination before and after transition.
  • Effective practice may involve prisons, justice liaison officers, community corrections, hospitals, guardians, behaviour support practitioners, housing providers, OTs, plan managers and local support teams.
  • This work cannot be reduced to generic connection activity. It requires confidence in risk, safeguarding, release planning, provider readiness and cross-system accountability.
  • Commissioning should explicitly preserve access to providers with demonstrated justice and forensic coordination capability.

Justice, prisons and remote communities

Why these contexts need deliberate design in the future SCC model

WIRU works in areas where specialist coordination can be the difference between a supported transition and a failed one. The consultation design should explicitly recognise the realities of custody-to-community work, forensic mental health interfaces and remote practice.

Custody-to-community pathway

A specialist coordinator may need to maintain continuity across several environments before a participant is safely established in the community.

HIGH-RISK TRANSITION ZONE • coordination quality matters most 1Custodyprison • secure careforensic settings 2Release planningrisk • housing • fundingservice readiness 3Transitionhandover • transportsupports commence 4Housing & supportsSIL • support workhealth • daily stability 5Communitycontinuityparticipation SPECIALIST NAVIGATION ACROSS THE WHOLE PATHWAYrisk • safeguarding • decision-making • provider readiness • housinghealth • justice • NDIS • continuity of relationship continuity cross-system work safe handover provider start-up community stability

Prisons and justice

Participants involved in prisons or community corrections often need coordinated release planning, suitable housing, behaviour support, health care connections, risk planning and careful engagement with multiple statutory systems. Service disruption at this point carries significant consequences.

Forensic and hospital transitions

Participants leaving hospital or forensic mental health settings require support that is clinically informed, time-sensitive and highly coordinated. Providers must be able to engage across ward teams, PBS, OT, guardianship, funding arrangements and community provider readiness.

Regional, rural and remote practice

Thin markets require more than online referral lists. They require local knowledge, outreach, travel capacity, flexible service models and realistic acknowledgement that support options may be limited or unavailable.

Cultural safety and connection

Local knowledge should include relationships with Aboriginal services, culturally safe engagement pathways, and an understanding that trust, community connection and safe contact pathways may determine whether coordination is possible at all.

Flexible delivery in regional, rural and remote communities

Thin markets call for a blended model rather than a one-size-fits-all service footprint.

BLENDED DELIVERY MODEL • combine the right elements for person and place PARTICIPANT & COMMUNITY local context determines the right mix Local knowledgeservices • networkslocal barriersknowledge of place Cultural connectiontrust • safe pathwayscommunity connectionAboriginal serviceslocal voices Outreach & travelface-to-face when neededtravel and outreachrealistic thin-market funding Telepracticecase conferencesfollow-upsupports remote access Specialist expertisecomplex disabilityjustice • risk • safeguardingnot always available locally Cross-region continuityservice follows participantthrough custody or hospitaland across relocation

Commissioning should allow these elements to be combined according to need rather than requiring every participant to fit the same delivery model.

Design implications

  • Future SCC design should allow specialist providers to retain participant relationships where they have relevant capability and established trust.
  • Regional service boundaries should not break continuity when a participant is detained, hospitalised or relocated for treatment or justice reasons.
  • Commissioning should consider outreach, travel, telepractice, cultural consultants and partnership models as part of quality remote service delivery - not as optional extras.
  • Assessing local knowledge should mean more than having an office in a region. It should include demonstrated relationships with disability, health, housing, justice and community systems.

Existing specialist workforce capability should not be unnecessarily lost during transition. Experienced coordinators hold significant knowledge about participants, systems and local service realities. Where current providers meet future requirements, there should be a practical pathway for those relationships and workers to continue.

Local knowledge should be assessed through practice and relationships: knowledge of housing, health, mental health, disability, Aboriginal services, justice and community networks, plus the ability to navigate real local barriers. A postcode or office lease is not enough.

The future model should support blended delivery: local workers where possible, outreach where necessary, telepractice when appropriate, and specialist metropolitan support where the participant needs expertise not available locally. Thin markets must be funded and judged realistically.

Participants facing justice involvement, psychosocial disability, cognitive impairment, homelessness, safeguarding concerns or limited decision-making support need access to specialist organisations that can coordinate assertively across systems. The new SCC model should preserve that pathway.

Transition arrangements and key recommendations

Transition will be critical. Government should announce commissioning requirements early, provide sufficient time for providers to prepare, avoid forcing providers to expand before commissioning decisions are known, and place continuity of participant relationships at the centre of implementation.

  • Participants should be advised well in advance if their coordinator or provider arrangements may change.
  • Small specialist organisations need a viable path to participate in the future model, including options other than being absorbed by larger providers.
  • Complex participants should transition gradually and only with careful planning.

Key recommendations

  1. Preserve participant choice and continuity of trusted relationships.
  2. Retain a genuine specialist pathway for high-complexity participants.
  3. Allow small specialist organisations to be directly commissioned or meaningfully partnered, not excluded by scale.
  4. Recognise professional capability, ethical accountability and cultural knowledge as core quality markers.
  5. Use complexity-based caseload expectations rather than simple numeric quotas.
  6. Protect conflict-free coordination, especially where organisations also deliver other NDIS services.
  7. Explicitly recognise specialist justice, prison and forensic coordination capability in commissioning design.
  8. Design remote and thin-market arrangements around outreach, travel, local relationships and cultural safety.
  9. Allow specialist providers to work across regional boundaries where that matches participant pathways.
  10. Provide early transition information so capable existing providers can plan responsibly and retain workforce.

Appendix A — Legislative, policy and professional references

WIRU's recommendations are informed by direct specialist practice experience and are considered alongside the legislative and regulatory framework governing the NDIS.

How these references are used: these sources provide the legislative, regulatory and professional context for the submission. They do not replace WIRU's practice-based observations, particularly in relation to justice, custody-to-community transitions, forensic mental health interfaces, regional and remote practice, and cross-system coordination.

Commonwealth legislationNational Disability Insurance Scheme Act 2013

The principal legislation establishing the NDIS, including its objects and principles, participant planning framework, provider obligations and the statutory functions of the NDIA and NDIS Quality and Safeguards Commission.

Federal Register of Legislation — NDIS Act 2013
NDIS RulesNational Disability Insurance Scheme (Provider Registration and Practice Standards) Rules 2018

These Rules set the registration and practice standards framework for registered NDIS providers. Schedule 6 contains the specialised support coordination standards, including specialised coordination, management of supports and conflict of interest.

Federal Register of Legislation — Provider Registration and Practice Standards Rules
NDIS Practice StandardsNational Disability Insurance Scheme (Quality Indicators for NDIS Practice Standards) Guidelines 2018

Part 7 sets quality indicators for specialised support coordination, including knowledge of high-risk and complex needs, crisis and support-breakdown planning, consultation with mainstream services and coordination of appropriate supports.

Federal Register of Legislation — Quality Indicators Guidelines
NDIS Code of ConductNational Disability Insurance Scheme (Code of Conduct) Rules 2018

The Code of Conduct applies to NDIS providers and workers, including unregistered providers, and establishes minimum expectations for safe, ethical and respectful conduct within the NDIS market.

Federal Register of Legislation — NDIS Code of Conduct Rules
NDIS CommissionSupplementary module: Specialist support coordination

The NDIS Commission's specialist support coordination module explains the relevant Practice Standards and quality indicators for registered providers working with participants who have high-risk and complex needs.

NDIS Quality and Safeguards Commission
Australian Government consultationSupport Coordination and Connection Reform Consultation

The consultation material sets out the proposed future Support Coordination and Connection service and the questions on service design, commissioning, provider models, workforce, safeguarding and transition arrangements addressed in this submission.

Department of Health, Disability and Ageing — SCC Reform Consultation
AASWSocial work in the NDIS

The Australian Association of Social Workers outlines the role of social workers within the NDIS and the contribution of social work knowledge and professional practice to disability support and coordination.

Australian Association of Social Workers — NDIS

Closing statement

  • WIRU supports reform that strengthens quality, consistency and safeguarding in support coordination and connection.
  • At the same time, reform should not inadvertently remove the very specialist capability that complex participants rely upon.
  • The future SCC service should create room for different provider types to contribute according to their strengths - including small, independent, specialist providers working in justice, hospital, regional and remote contexts.

Prepared by WIRU

Authorship and cultural consultation

This submission was prepared by Susie Waterman, Director of WIRU Community Health & Well-Being Pty Ltd, in consultation with Melissa Thompson, WIRU's First Nations Cultural Consultant.

Susie Waterman
BA (Behav. Sci.), MSW
AASW Accredited Social Worker
Director
WIRU Community Health & Well-Being Pty Ltd
Melissa Thompson
First Nations Cultural Consultant
WIRU Community Health & Well-Being Pty Ltd

External support and endorsement

  • WIRU welcomes letters of support or endorsement from government agencies or senior officers who wish to support this submission.
  • Separately authorised letters of support or endorsement can be attached as supporting material to demonstrate shared confidence in the importance of specialist, relationship-based navigation for participants with complex needs.

Contact

WIRU Community Health & Well-Being Pty Ltd
hello@wiru.org
South Australia | Queensland

Prepared in response to the Support Coordination and Connection Reform consultation questions released for submissions closing 2 October 2026.

Terminology used in this submission

Key terms and acronyms used throughout this submission are defined below for ease of reference.

SCCSupport Coordination and Connection
SSCSpecialist Support Coordination
NDISNational Disability Insurance Scheme
NDIANational Disability Insurance Agency
AASWAustralian Association of Social Workers
PBSPositive Behaviour Support
OTOccupational Therapist / Occupational Therapy
SILSupported Independent Living