SDA compliance issues are becoming increasingly prevalent across Australia. In response to a recent podcast episode, Bruce Bromley shared his current observations on the state of play within the Specialist Disability Accommodation (SDA) space. With his permission, we’ve published his unedited thoughts below to inform ongoing industry discussions.
A Shift Away from Apartments
There has been a noticeable move away from apartment requests, both by participants and developers. I attribute this to the difficulty of getting participant plans approved or rates increased. I think some providers are overselling when they understate the difficulty of this.
We also see fewer HPS participants moving into apartments in lieu of FA due to SIL providers not wanting to manage them, and due to participants not being funded for apartments. SILs’ preference is typically to have three participants sharing a house. It is easier to manage three high-support participants in one dwelling than to travel between participant apartments. While participants may prefer a maximum of two within a dwelling, we see NDIA approving many plans at three share.
Finance Blacklisting and Location Shifts
Since the finance blacklisting, we have noticed a distinct move from new subdivisions to established suburbs. In addition to the small/medium developers, several large interstate providers from NSW and QLD, in addition to existing VIC developers, are rolling out new houses at a large scale in established inner suburbs.
Planning Roadblocks: The Impact of CHiMP
Developments around certain parts of Melbourne and areas such as the Mornington Peninsula have slowed significantly (some developers have pulled projects) due to the requirement to achieve a CHiMP (Cultural Heritage Management Plan ) during the planning process if the development is considered to be High Impact (for example, triggered by ‘Community Care’ classification as a result of the building surveyor applying a BCA Class 3 residential care classification). This has caused additional expenses in excess of $30-40K for reports, excessive delays, and huge risks for the construction phase if anything of cultural significance is identified, which could effectively shut the project down.
Risk of Oversupply in Inner Suburbs
Within the next 3 years, the inner suburbs may start reaching a point of oversupply, like new subdivisions that have been blocked from obtaining finance.
Rise in Non-Compliant SDA Builds
Over the last 24 months, we have observed a high volume of non-compliant SDA houses and apartments being delivered to the market.
Key Issues Identified During PEER Reviews
Nationally, demand for our PEER review and pre-acquisition due diligence inspection services has increased significantly for investors, investment and finance institutions, and banks.
Typical issues we have identified during these inspections include:
• Redundant power, such as UPS or generators, in newly built, fully enrolled and occupied HPS dwellings not being installed. It cannot be overstated how dangerous this is for participants.
• Bathroom wall reinforcement to all walls that have not been installed in houses and apartments.
• No structural inspection and certification by a registered structural engineer of the hoist roof structure (mandatory SDA requirement), with assessors relying on roof truss structural design computations only, without the mandatory final inspection.
• The required level surface of a minimum 2070 x 1540mm at the letterbox within the boundary is not provided.
• Non-compliant path of travel from the boundary to the house entrance (FA/HPS).
• Non-compliant glazing, doors, and plumbing fittings in Robust housing.
• Then you see Hybrid designs that include Robust with height-adjustable benches, ceiling fans and other accessible elements, etc, which will be ripped out on the first day and weaponised by participants. Most of these hybrid designs we have assessed do not fully comply spatially with the FA & HPS categories that the owners were promised.
• Incorrect ovens and dishwashers were installed.
• Non-compliant shower gradients that are supposed to be within 1:60-1:80, as steep as 1:20.
• Grabrails, backrests and shower seats are installed in bathrooms when the design standard explicitly states that they must not be provided unless a participant requires them. Ironically, if a participant needs grabrails, the allied health team, including OTS and Physios, design them, and we have not seen one request ones that meet AS 1428.1.
• Non-compliant switches, dimmers and task lighting, as well as the incorrect number of GPOs within bedrooms.
NDIA Compliance Action May Be Underway
We have heard from other assessors that the NDIA has already started to organise random inspections of previously certified houses to identify issues. This was initially raised in one of the NDIS Assessor CPD sessions last year, so we can only hope these will continue, as a lot of what is currently being delivered can best be described as crap and ones without UPS, no structural certification are putting lives at risk. If significant issues are identified, I believe these dwellings must be unenrolled until they are made compliant.
Final Thoughts
As for the SDA provider side of things, it is becoming like the wild west. But I will leave that for another day.
Contact Bruce
Bruce Bromley is one of Australia’s most respected SDA Assessors, with extensive experience in compliance audits, peer reviews, and pre-acquisition inspections.
📧 bruce@equalaccessgroup.com.au
🌐 www.equalaccessgroup.com.au
Please note: Bruce is not affiliated with our organisation. We are sharing his insights with permission to support industry-wide learning.
Have thoughts on Bruce’s perspective? If you’d like to share your comments or have any questions you’d like our team to answer on a future podcast, reach out to us at 1300254397.