Policy Submissions

Policy Submissions

Caring crosses all levels of government and the many agencies that provide health and community care services. Our policy team works with many different bodies, in many different ways, to promote the needs of caring families.

2020 Submissions

September 2020 - Beyond the rhetoric of choice and control: building fairness and equity into the NDIS Submission

The NDIA is undertaking a review of the current support coordination service model.

Carers Victoria's submission recommends that the NDIA significantly reforms its provision of support coordination by recognising it as a reasonable and necessary support for carers. Doing so will build fairness and equity into the Scheme for carers.

Download the submission here.

July 2020 - Whole of Government LGBTIQ Strategy Submission – Carers Victoria

Carers Victoria is proud to make this contribution to the Victorian Whole of Government LGBTIQ Strategy (the Strategy). For many years, Carers Victoria has worked to ensure that our carer services are LGBTIQ inclusive and that LGBTIQ carers feel supported in the community. This has recently been recognised through Rainbow Tick accreditation.

The limited research that is available suggests that LGBTIQ people are more likely to be carers than non LGBTIQ people. In a national survey of the health and wellbeing of 3,800 gay, lesbian, bisexual and transgender Australians, more than one quarter of respondents identified as carers. Previous Carers Victoria research into the challenges LGBTIQ carers face compared to non-LGBTIQ carers suggests they are more likely to experience high rates of discrimination and victimisation, less likely to access any form of service and must manage heteronormative assumptions about their lives. This can result in LGBTIQ carers seeking support late and through crisis.

LGBTIQ carers may not have family who can support them, so they rely on other community members, friends, or partners to provide informal respite.

This submission contains detailed recommendations from research and consultations Carers Victoria has had with carers from LGBTIQ communities.

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June 2020 - Department of Health - Aged Care Worker Regulation Scheme Consultation paper

Carers Victoria strongly supports the establishment of an aged care worker registration scheme which is robust and prioritises the safety and dignity of older people as recipients of aged care services, their carer(s) and other family members.

Aged care worker registration is an important mechanism in addressing inadequate training and the significant level of harm which occurs every day against older people in their homes and residential aged care settings, their families and carers. Carers Victoria expects worker registration to be one mechanism in a broader strategy to increase quality and safety in the delivery of aged care services.

Introducing an Aged Care Worker Registration Scheme will be essential in sustaining Victoria’s over 700,000 family and friend carers. The Scheme will engender trust in workers who support older people with care needs. With a well-regulated sector and increased professionalism of the workforce, the community can avoid crisis-driven services for carers and instead provide early-intervention assistance.

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June 2020 - Skills for Victoria’s Growing Economy

It is very challenging for carers to balance their caring responsibilities with work and study. To succeed in their studies, carers require educational institutions to have a greater understanding of their experiences resulting in increased support and flexibility. Carers Victoria has chosen to focus its submission around the questions posed in the ‘Lifelong Learning’ section of the Issues Paper.

  • Completing: Why do students leave courses before completing? Have you (or someone you know) ever left a course before completing it?
  • Decision-making: How did you decide what to study? Who influenced your decision? What additional information would have helped?
  • Additional support: Have you, or someone you know, ever needed extra support during your study? What helped, or what might have helped?

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May 2020 - State Disability Plan 2021-24

Carers Victoria submitted a response to the Office of Disability’s Consultation Paper regarding the next State Disability Plan for Victoria. As legislated in the Disability Act (2006), the Victorian Government is required to develop a plan to increase the inclusion of people with disability in a variety of domains. Carers Victoria’s main recommendation was the Plan be complementary to the Victorian Carer Strategy 2018-22. Other recommendations included better recognition of carers with disabilities, promotion of the Guardianship and Administration Act (2020) and leadership about the Government’s submissions to the Disability Royal Commission as a funder and provider of services and a broad understanding of how it intends to respond to the Commission’s recommendations.

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March 2020 - Parliamentary Inquiry into Homelessness

The Legal and Social Issues Committee of Victorian Parliament held an inquiry into homelessness to look at the changing scale and nature of homelessness across Victoria; the many social, economic and policy factors that impact on homelessness; and the policies and practices from all levels of government that have a bearing on delivering services to people experiencing or at risk of homeless.

Carers Victoria’s provided the Committee with an in-depth description of the economic disadvantage many carers experience, especially older female carers and made recommendations aimed at increasing the availability of housing to rent or buy to carers on low incomes. The submission also made recommendations about increasing support for families of children with disability, adults living with ageing parents and people living with mental illness.

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February 2020 - Disability Worker Regulation Scheme proposed registration standards and proposed regulations

The recently established Disability Worker Registration Board of Victoria together with DHHS consulted on proposed registration standards and regulations due to come into effect 1 July 2020. Carers Victoria supports the establishment of Disability Worker Registration which was a recommendation of the Parliamentary Inquiry into Abuse in Disability Services (2015). Carers Victoria argued registration is an important mechanism to address the significant level of abuse, exploitation and violence which occurs every day against people with disability, their families and carers. The submission argued the proposed registration standards were unlikely to provide confidence to clients that Registrants will have minimum qualifications, be required to demonstrate or develop expertise in specific areas of practice or undergo adequate professional development to maintain their skills. While the proposed regulations will be implemented from 1 July 2020, the Government decided to postpone the introduction of registration standards until July 2021, citing the COVID-19 pandemic. Carers Victoria hopes delay will enable the Board to develop more robust registration standards which put the safety of people with disability, families and carers first.

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January 2020 - Productivity Commission Inquiry into Mental Health Response to Draft Report 

This national inquiry commenced in November 2018 with the purpose of understanding the effect of mental health on people’s ability to participate in and prosper in the community and workplace, and the effects it has more generally on our economy and productivity.

Carers Victoria has been working to ensure that the Productivity Commission (the Commission) understand the needs of carers, in terms of their role as a carer, but also relating to carers’ own health and wellbeing.

In December 2019, the Commission published its Draft Report. Carers Victoria has just submitted its response.

The response focuses on carers in mental health settings, at schools, in workplaces and the financial impacts of providing informal or unpaid care. Carers Victoria recommends the Commission further considers the needs of carers from diverse communities; issues relating to psychosocial disability and the NDIS; and issues of affiliate stigma experienced by many carers, especially mental health carers.

The Commission will provide a final report to the Australian Government on 23 May 2020.

For further information and to subscribe for updates see the Commission’s website.

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January 2020 - Inquiry into Expanding Melbourne's Free Tram Zone

Carers Victoria welcomes the Committee’s Inquiry into Expanding the Free Tram Zone.

Carers Victoria supports point one in the Terms of Reference of this Inquiry. Expanding the Free Tram Zone to cover the routes listed will ease the transport expenses of carers required to attend hospital for their own health care and/or for the person they are caring for.

The submission recommends additional actions which would make public transport travel more accessible for carers and people receiving care.

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2019 Policy Submissions

December 2019 - Assessing the Framework for Training Drivers of Wheelchair Accessible Vehicles

Commercial Passenger Vehicles Victoria is the new regulator of the commercial passenger vehicle industry which includes unbooked rank and hail taxi services and booked services (taxis, hire cars and rideshare vehicles). Carers Victoria recommended commercial passenger vehicle drivers in Victoria undertake disability awareness training and the Regulator:

  • Determine if it is appropriate driver’s obtain insurance for damage to passenger goods,
  • Regularly assess the viability of the WAV market and adjust payments as required, and
  • Appoint an economist skilled in thin markets to report on optimising the WAV market.

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December 2019 - Residential Tenancies Amendment Act (2018) proposed Regulations

The Residential Tenancies Amendment Act is one of the most significant reform undertaken in the State’s history. It is intended to better support rental providers and renters to enter into mutually beneficial rental agreements and facilitate a fairer balance between their rights and responsibilities than current arrangements do. Carers Victoria endorsed many aspects of the proposed Regulations, such as the inclusion of information statements on unlawful discrimination in application forms – this applies to carers and people they care for. Other recommendations Carers Victoria made to better protect people who provide unpaid care to family members and friends include:

  • Amending the proposed Regulations to expand the range of information that VCAT must consider when determining an application to terminate a rental agreement for people who are in care relationships with individuals who display behaviours of concern.
  • Including a safe and reliable cooling appliance in the Minimum standards.
  • Mandating 28 days for rental providers to respond to home modification requests permitted under Section 64 Amended of the Rental Tenancies Amendment Act 2018.
  • Allowing renters and rental providers to negotiate the means by which they communicate with each other and mandating accessible communication between renter and rental provider.

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July 2019 - Royal Commission into Victoria’s Mental Health System – Initial Submission

Carers Victoria has chosen to focus its submission on the mental health and wellbeing of Victoria’s 736,600 unpaid family and friend carers.

One in eight Victorians is an unpaid family or friend carer. It is critical the Royal Commission recommendations include measures and resources to improve the mental health of Victorian carers.

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June 2019 - Victorian Parliamentary Inquiry regarding Commercial Passenger Vehicles Victoria

Carers Victoria made a submission to the Victorian Parliamentary Inquiry into Commercial Passenger Vehicles Victoria.

Carers needs are being represented in the regulation of the dynamic taxi, ride share and hire car industry.

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June 2019 - NDIS Thin Markets

The NDIS has used the private sector to provide services to people with a disability. Thin Markets occur where demand and supply do not deliver a good deal. Carers Victoria discussed how carers and the people they care for can be better off when they exist in a Thin Market e.g. living in isolated area.

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April 2019 - Productivity Commission Inquiry into Mental Health – Initial Submission

Carers Victoria welcomes the opportunity to contribute the Productivity Commission’s Inquiry into Mental Health. Carers Victoria has chosen to respond to a selection of the questions raised in the Issues Paper.

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2018 Submissions

December 2018 - Submission National Arts and Disability Strategy Discussion Paper

Carers Victoria made a submission in response to the National Arts and Disability Strategy Discussion Paper (An initiative of the Meeting of Cultural Ministers). Carers Victoria outlined the importance of better recognition and support for families and carers in the Strategy which should fully understand the regulatory, legislative and funding changes since the previous Strategy was adopted particularly their impact on the disability sector, families and carers. Carers Victoria recommended the renewed National Arts and Disability Strategy more explicitly emphasises the diversity of carers and indeed the ways families and carers engage in the Arts, as creative and cultural professionals, through participation in recreational creative activities and as audience members.

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November 2018 - Submission Australian Building Code Board Accessible Housing Options Paper

Carers Victoria made a submission in response to the Australian Building Code Boards Accessible Housing Options Paper which requested community feedback about minimum standards of accessibility for all new residential buildings to be incorporated into the National Construction Code (NCC). Currently, residential buildings such as homes, units and townhouses built by individuals do not need to meet minimum accessibility standards. Some State and Territory Governments have committed to building public housing that meets accessibility standards but this only accounts for a small proportion of residential housing built in Australia. Carers Victoria believes accessible housing is of critical importance to people in care relationships particularly those with mobility support needs from disability, illness or advanced age. Carers Victoria recommended a minimum Liveable Housing Design Guidelines – Silver Level (with all 7 elements) be applied to all new residential housing to increase supply of accessible housing to reflect Australia’s changing population and community expectations.

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August 2018 - Draft Single Charter of Aged Care Rights Submission

Carers Victoria made an online submission in response to the Draft Charter of Aged Care Rights Consultation Paper. Carers Victoria supports combining the four current Charters into a single Charter and extending it to people receiving Commonwealth Home Support Program services. Carers Victoria’s recommendations for improvement relate to greater emphasis on the value and contribution of older people in our society, and on recognising carers and care relationships.

Thanks to everyone who contributed to this submission.

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July 2018 - Submission to the Supported School Transport and the National Disability Insurance Scheme Discussion Paper

The Federal Department of Social Services (DSS) recently invited comment on the proposal to transition State and Territory-based programs of Supported School Transport to the National Disability Insurance Scheme. In Victoria Supported School Transport is offered to students who meet criteria of functional impairment and live within a specific distance of a specialist school. Carers Victoria’s primary recommendation was keeping the current State and Territory-based system until the disability services market ushered in by the NDIS has sufficiently matured. While we acknowledge the current Victorian system can be restrictive for parents and children by only providing school transport if a child attends a specialist school, Carers Victoria is concerned a transition to the current NDIS will disrupt children’s educational opportunities and NDIA planning processes will increase stress on families and carers. In addition Carers Victoria recommended the community be given more opportunity to comment on further refinements of the proposal. One way to facilitate this is to release any data obtained from the NDIS trial of market-based supported school transport in the Barwon region of Victoria in 2017.

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June 2018 - Submission to the Specialist Disability Accommodation Pricing and Payments Framework Review

Carers Victoria developed a submission for the NDIS Supported Disability Accommodation (SDA) Pricing and Payments Framework Review. We focused on constrained opportunities for NDIS participants and carers in the current Framework which does not appear to support a truly innovative and ambitious market for SDA in Australia. Carers Victoria recommended the Framework mandate the NDIA to regularly publish data on the number of NDIS participants who test their eligibility for SDA and how many are seeking to move from existing SDA stock to more contemporary community living. The NDIA needs to stimulate SDA in sufficient volume and place NDIS participants, their families and carers at the centre of decisions about SDA allocations.

In addition to our submission, Carers Victoria was also pleased to endorse the Submission to the NDIS SDA Pricing and Payments Framework Review authored by the Summer Foundation. This submission was jointly made by more than 20 organisations that advocate for people with disability or are providers of SDA housing. This comprehensive submission discussed pricing assumptions and the interface with NDIS SDA Rules, the recently released Provider and Investor Brief and other operational processes.

www.summerfoundation.org.au

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Response to DHHS Draft Disability Action Plan

Carers Victoria commented on the Department of Health and Human Services draft Disability action plan. The plan is intended to guide DHHS’s external and internal capacity building to reduce barriers people with disability face. Carers Victoria’s response focused on the lack of carer recognition and inclusion as people with disability themselves or as crucial supporters and advocates for people with disability. We recommended the plan include the Victorian Carers Recognition Act and National Disability Agreement in its legislative and policy context. We also suggested DHHS should provide targeted early interventions for families to avoid crises that result in referrals to the child protection system, recognition of people with disability over the age of 65 and support older parents of adults with disability to plan for the time when they are no longer able to care.

Download Submission

Download Draft Disability Action Plan Document

April 2018 - Recognising Carers as Service Users in Mental Health Data

Pre Budget Submission 2018