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Proposed NDIS Specialist Disability Accommodation Design Standard

Farah Madon

Brief overview of the current requirements for SDAThe SDA Price Guide Table 3 provides some guidance on the requirements for each of the four design categories.

Improved Liveability

Reasonable level of physical access and enhanced provision for people with sensory, intellectual or Cognitive impairment

Robust

Resilient materials, reducing the likelihood of reactive maintenance and reducing the risk tothe participant and the community

Fully Accessible

High level of physical access provision for people with significant physical impairment

High Physical Support

High level of physical access provision for people with significant physical impairment requiring high levels of support

- At this point there is no certification process available for SDA. Certification can only be provided for Livable Housing Silver or Platinum and not SDA.

- The closest thing that can be provided for SDA dwellings is something like a Statement of Consistency with the Table 3 of NDIS SDA Price Guide 2019-20 where a comparison is made between the proposal and the items listed in the Table 3.

- At this point some suppliers are taking a risk of self assessment for both LHDG and SDA requirements as there is no regulation that actually requires the property to be registered with LHA for claiming SDA funding.

Brief overview of the current requirements for SDA

Why the need for NDIS SDA ( Specialist Disability Accommodation ) Design Standard (DS) ?

- In an ideal world, each participant would be able to design their homes based on their individual requirements. However for NDIS to be able to fund dwellings, it needs to be satisfied that the dwellings meet a minimum level of design standards.

- A number of items listed in Table 3 NDIS SDA Price guide (Description of Minimum Design Category Requirements) are subject to interpretation. For example wordings in the table such as “Consideration must be given” could be used as a loop hole for non provision of certain features.

- Heavy reliance of Livable Housing Design Guidelines (LHDG) even though LHDG is designed for Aging in place rather than having specific features appropriate for People with Disabilities that require use of a wheelchair.

- 3rd Party Independent Certification of SDA dwelling is preferred to self-assessment by providers.

The proposed NDIS SDA ( Specialist Disability Accommodation ) Design Standard (DS).aims to provide a minimum set of requirements for the four design categories of:

• Improved Liveability• Robust• Fully Accessible and• High Physical Support

NDIS SDA DS are being developed based on feedback received from :

NDIS Housing team

NDIS SDA Reference Group

LHA Industry Reference Group

LHA SDA Steering Committee

Disclaimer: It is important to note that the proposed SDA DS are still undergoing final updates and therefore may vary from the items discussed in this presentation. Release date is anticipated some time later this year.

Drawing on some of the relevant requirements of LHA as referenced in the SDA Price Guide

Addition of elements that are specifically suitable for people with Disabilities based on the majority feedback received and case studies provided by NDIS of people who were eligible for SDA funding

NDIS SDA Design Standard

It is proposed that compliance will only be required with NDIS SDA Design Standard and will not require separate LHA Silver or Platinum level assessment.To provide more certainty to the market, it is proposed that the assessment can take place at 2 stages, design stage (not-mandatory) and post construction stage (mandatory)

Technical consultation process- LHA SDA Industry Reference Group (LHA IRG)The following SDA Housing providers and other peak National bodies were consulted resulting in over 700 comments on Draft 1 itself.

Association of Consultants in Access AustraliaHousing Industry AssociationReal Estate Institute of AustraliaAustralian Institute of ArchitectsUnity HousingDisability Services ConsultingBlueCHPMaster Builders AustraliaInHousingHousing Choices AustraliaInstitute of Access Training AustraliaNational Disability ServicesIllowra ProjectsJames HardieLendlease Livable Housing AustraliaGlobal Mark

PowerHousingStocklandHume Community Housing AssociationNorth Coast Community HousingPhysical Disabilities AustraliaAV JenningsOccupational Therapists AustraliaSDA Alliance represents the following SDA developers- Compass Housing- Young care- Access Housing- Anand Group homes- Hume Community Housing- Ability SDA- Access Accom- Access 2 Place Housingand a number of Access Consultants, Architects and Service Providers.

Case studies provided by NDIS for various design categoriesBased on the case studies provided by the NDIS, indicates that

- Participants allocated dwellings in the Improved Liveability design category will be people with sensory, intellectual or cognitive impairment. They will likely not require use of a mobility aid such as a wheelchair.

- Participants allocated dwellings in the Robust design category will require dwellings made of Resilient materials. They will likely not require use of a mobility aid such as a wheelchair.

- Participants allocated dwellings in the Fully Accessible design category will require use of a mobility aid such as a wheelchair.

- Participants allocated dwellings in the High Physical Support design category will require use of a mobility aid such as a wheelchair and will also require additional supports.

There is no solution that will fully satisfy the requirements of all participants and a participant requirements may not neatly fit into just one of the design categories.

There is never going to a DS that will satisfy all stakeholders

The biggest challenge for the development of DS was to be able to reasonably answer the questions

IS THE DESIGN FIT FOR PURPOSE?

Common feedback/issues raised by the LHA Industry Reference Group members mainly included comments in regards to Fully accessible, High Physical Support and Robust design categories.

The biggest concern raised was the suitability of relying heavily on LHA when

LHA DESIGN GUIDE WAS SUITABLE FOR AGING IN PLACE BUT NOT SUITABLE FOR USE BY A PERSON WHO REQUIRES USE OF A WHEELCHAIR FOR INDEPENDENT MOVEMENT.

- The 2017 Price Guide referenced LHDG Edition 3, however the recent Price Guide references LHDG Edition 4 in which Accessible path of travel from the site boundary is no longer mandated, which would mean that a person requiring use of a wheelchair would need to be able to drive themselves or rely on someone to drive them to leave and come back to their own home.

Common feedback/issues raised by the LHA Industry Reference Group members mainly included comments in regards to Fully accessible, High Physical Support and Robust design categories.

- Door circulation spaces were not a requirement as per LHA Platinum level which may mean a person requiring use of a wheelchair for mobility would not be able to independently open / close doorways to their own home unless door automation was provided from the very beginning.

LHA DESIGN GUIDE WAS SUITABLE FOR AGING IN PLACE BUT NOT SUITABLE FOR USE BY A PERSON WHO REQUIRES USE OF A WHEELCHAIR FOR INDEPENDENT MOVEMENT. (continued)

- Space required in front of a WC pan for LHA Platinum level is 1200x1200mm - the 90th percentile wheelchair size is 800x1300mm, - a stand alone LHA Platinum level toilet does not accommodate a 90th percentile wheelchair

SOLUTION FOR INDEPENDENT USE BY A PERSON WHO REQUIRES USE OF A WHEELCHAIR (FULLY ACCESSIBLE AND HIGH PHYSICAL SUPPORT DESIGN CATEGORIES)

IS TO ALLOW FOR CIRCULATION SPACES AS PER AUSTRALIAN STANDARD AS1428.1 FOR DOOR CIRCULATION SPACES AND CIRCULATION SPACES IN ANY 1 BATHROOM

- AS1428.1 has been used in design for residential dwellings for SEPP (NSW State Environmental Planning Policy) for Seniors and People with a disability since 1982.

- To avoid ‘institutional use’ and flexibility of use of different participants for the life time of the dwellings, the proposed Draft DS does not require initial installation of any grabrails or back rests or other fixtures such as shelves or clothes hooks or toilet paper holder as per AS1428.1.

- CIRCULATION SPACES for independent use of 1 WC pan, 1 shower and 1 hand wash basin are proposed in the Draft DS

Providers are encouraged through best practises to go above and beyond the DS to develop dwellings that go above and beyond the standard.

Participants have a choice in selecting their homes so I anticipate that the quality of future SDA projects will go above and beyond the minimum SDA design standards.