Publications, Submissions and Position Papers
Our Systemic Advocacy team have published a number of documents related to the needs, concerns, and issues that are of key interest to WA’s lived experience community.
Submissions are documents that we have submitted to various stakeholders about some of the key issues that impact consumers, whilst our briefing papers are designed to keep our members informed about the happenings within the mental health space.
We publish all these documents and archive them here to keep members fully informed of what we stand for, and the views and perspectives that shape our systemic advocacy work.
Position Papers
Restrictive Practices – In this paper, we explain that CoMHWA wholeheartedly supports the complete elimination of restrictive practice in all mental health contexts. We outline our recommendations for actions that must be part of a strategy to record, reduce and ultimately eliminate restrictive practice, even those practices that are not sufficiently recognised or understood in the health system
Supported Decision Making – In this paper, we state that it is our position that rather than having decisions made on behalf of or in the ‘best interests’ of a person, we want to see a world where a person is always presumed to have some capacity to make decisions, and that some people simply need more or less support to make those decisions.
Involuntary Treatment – This paper explores CoMHWA’s stance on Involuntary Treatment, which we argue is not therapeutic and breaches a person’s human rights. We argue for alternatives to Involuntary Treatment, and for a more nuanced understanding on how to meet the needs of people experiencing great distress without causing them further trauma and harm. Please keep your eye on the next newsletter for a new position paper from our Systemic Advocacy team.
On the WA government’s Response to Recommendations of the Disability Royal Commission Report- In late 2024, the WA Government released its response and Implementation Roadmap for the Disability Royal Commission (DRC) final report. This outlines plans to address accepted recommendations and consider others. Our positions reflect the key concerns raised by our members, and we strongly advocate for the WA Government to prioritise the rights and inclusion of people with psychosocial disability in its implementation efforts.
2025 Submissions
November
Feedback to the Mental Health Commission’s Trauma-Informed Approach Guide – CoMHWA submitted feedback to the draft Trauma-Informed Approach Guide authored by the Mental Health Commission. While much of our feedback focused on language, tone and purpose of the document, our major suggestion for change was that the Guide must acknowledge the harms done by restrictive practice, and that a trauma-informed approach must commit to eliminating such practices.
September
Submission to the Mental Health and Alcohol and Other Drug Proposed Strategic Directions 2025-2030 – We gave feedback to the Mental Health Commission’s draft Strategic Directions, drawing from our own submission made in November 2024 during the initial consultations. In our feedback, we ask for more specificity and a coherent focus for the strategic directions, as well as a stronger and clearer commitment to system transformation.
July
Submission to the NDIS Support Rules consultation – CoMHWA made a submission to the Department of Social Services conveying our members’ experiences of how the Support Rules have created confusion, eroded supports and reduced choice and control. In particular, CoMHWA has heard that the lists are not helpful in bringing clarity and do not allow for sufficient flexibility. Clarity and flexibility are the qualities most participants desired in an NDIS supports rule going forward. While CoMHWA would prefer a principles-based approach instead of the lists, given the NDIA’s stated intentions to keep lists, these should be designed in a way that avoids blanket exclusions affecting needed supports, and should make space for innovation and flexibility.
Submission to the Productivity Commission Interim Response – We gave feedback on the findings of the Productivity Commission’s Interim Response to their review of the National Mental Health and Suicide Prevention Agreement. Overall, we commended the report for finding that the current system of supports is not improving the lives of people experiencing mental health challenges and supported many of their recommendations. We were also able to respond to some of their requests for information, including case studies where peer work has been successfully embedded into clinical settings. Further, we added recommendations of our own that the Productivity Commission has not yet addressed, including provisions for advocacy and service navigation and the commitment to ongoing funding for successful pilot programs.
Submission to WA Firearms Act 2024 Inquiry – CoMHWA has raised concerns about unintended consequences of the new Firearms Act, particularly its impact on people seeking or renewing licenses while also managing mental health challenges. Our submission warns that mandatory mental health assessments may deter people – especially in regional, rural or remote WA – from seeking help due to fears of losing their licence, and may strain trust between GPs and communities. We call for genuine co-design with affected communities and careful review of how mental health is assessed in this context.
June
Submission to the Next Steps in Supported Employment consultation – CoMHWA has submitted feedback to the Department of Social Services, urging an end to segregated employment and calling for a transition to inclusive, open workplaces that support people with psychosocial disability. We advocate for reforms to Disability Employment Services, national rollout of evidence-based programs like Individual Placement and Support (IPS), and a greater role for peer-led initiatives. Our submission is based on strong consumer consultation and emphasises the need for employment to be person-centred, flexible, and rights-based.
May
Joint Submission on Youth Mental Health Models of Care (CoMHWA and YDAN) – CoMHWA and the Youth Disability Advocacy Network (YDAN) submitted joint feedback to the Models of Care Consortium on youth mental health services. We raised concerns about the lack of early and meaningful involvement of young people with lived experience in the consultation process. Our submission calls for systemic reform that centres co-design, expands peer support, addresses service gaps (including in regional areas and during the transition to adult services), and moves beyond narrow clinical models. We advocate for more inclusive, trauma-informed, and flexible supports that reflect the real lives of young people.
Submission to Consultation on the Assistance Animals National Principles – CoMHWA’s submission highlights the need for the national principles to better recognise and support the rights and needs of people with psychosocial disability who use assistance animals. We called for principles that are co-designed with people with lived experience and that are inclusive of psychiatric and sensory support animals. Our submission stresses the need for standardised national systems that reduce barriers and promote both accessibility and animal welfare, while addressing inequities in current laws, accreditation processes, and NDIS access.
Submission to the Law Reform Commission of WA – Guardianship and Administration Act Review – CoMHWA has provided a detailed submission to the Law Reform Commission’s review of the Guardianship and Administration Act 1990 (WA), calling for the Act to be brought into line with contemporary human rights standards. We call for a supported decision-making model that centres the will and preferences of the person, replaces outdated and paternalistic language, and addresses the disproportionate impact of the Act on mental health consumers – particularly Aboriginal people and those with highly stigmatised diagnoses.
April
Submission to WA Suicide Prevention Framework 2025-2035 – CoMHWA consulted with consumers across metropolitan and regional WA to inform our response to the state’s Suicide Prevention Framework. Consumers called for holistic, place-based responses that are culturally safe, peer-led, and responsive to local needs. Key themes included the urgent need for safe housing, better integration of services, reduced stigma, and non-clinical supports that are accessible outside of crisis. CoMHWA’s submission centres the voices of lived experience and highlights the importance of local connection, community wellbeing, and trust-building.
March
Submission to consultation on Mandatory Registration of Platform Providers – CoMHWA has submitted our feedback to the NDIS Quality and Safeguards Commission Consultation on Mandatory Registration of Platform Providers. CoMHWA heard from participants with psychosocial disability that mandatory registration of Platform Providers should be designed to promote participant choice, control, and autonomy, and that the NDIS Commission must be mindful of potential impacts on accessibility and affordability of supports. In this submission CoMHWA echoes the disappointment many participants expressed to us that they were not more meaningfully involved with the decision-making and planning that has led to the making of these changes that will impact their systems of support.
Submission to consultation on Mandatory Registration of Supported Independent Living (SIL) and Support Coordination – CoMHWA has submitted our feedback to the NDIS Quality and Safeguards Commission on the Mandatory Registration
of Supported Independent Living (SIL) and Support Coordination Consultation. CoMHWA has heard from participants that mandatory registrations are likely to impact significantly on the ability of NDIS participants to access the supports they need. Participants are already unable to find providers who are well informed around psychosocial disability, and told us that recently implemented changes to NDIS legislation and supports have resulted in them experiencing a further loss of supports. CoMHWA believes that there is a need for the NDIS Commission to take positive action to promote the development of more support options and promote choice and control – registration alone will not accomplish such a goal.
Submission to the Productivity Commission Review into the National Mental Health and Suicide Prevention Agreement – CoMHWA has provided feedback to the Productivity Commission, calling for the Agreement to move beyond a dominant medical model and to meaningfully embed lived experience and peer-led alternatives in service design and delivery. We recommend lived experience governance, culturally safe Aboriginal-led services, and stable funding for peer-led models such as Alternatives to Suicide. CoMHWA members also called for reform of language, service accountability, and better recognition of diverse and community-based understandings of mental health and distress.
February
Submission to the NDIS self-directed supports consultation – CoMHWA has submitted our feedback to the Department of Social Services’ consultation on Self-Directed Supports Registration. In this submission, CoMHWA focuses on providing feedback informed by the experiences of participants accessing NDIS for supports with psychosocial disability. We provide feedback on the proposed approach to registration for participants who want to self-direct their supports, the nature of requirements participants will need to meet to maintain registration, and the nature of support that should be offered to participants throughout the process.
CoMHWA heard from participants that while it is important to explore ways of ensuring that NDIS supports are high-quality and safe, enabling participants to access unregistered providers without placing barriers in their way is important to maintain participants’ choice, control, and capacity to access supports they need. We emphasise the need for easily accessible, straightforward and clear processes around registration and meeting obligations, and genuinely supportive information and contact from the NDIS Commission to facilitate participants’ capacity to self-direct supports.
January
Primary Health Network Business Model Review – Our submission gives feedback in addition to offering our full support for the submission made by the National Mental Health Consumer Alliance (NMHCA) to this Review. Their submission outlines crucial recommendations that align with our shared commitment to improving PHN commissioned mental health services, fostering more inclusive, person-centred care, and promoting better outcomes for all individuals living with mental health challenges. We stand united in advocating for the importance of ensuring that the perspectives and needs of mental health consumers are central to the Review process.
Other Publications
Literature review – Systemic Racism and Aboriginal and Torres Strait Islander People’s Social and Emotional Wellbeing – This literature review, written by our Systemic Advocacy team and reviewed by our Indigenous Policy and Research Officer, explores what has been written about systemic racism and its impact on Aboriginal and Torres Strait Islander people’s social and emotional wellbeing (SEWB). The review identifies several key themes describing systemic racism in mental health and SEWB service systems and concludes with recommendations on future actions CoMHWA can take.
Summary of Literature review– This is a 3-page summary of the literature review that focuses on unpacking the key themes and findings from the review and what priority areas should be investigated by CoMHWA.
Establishing an Urgent Mental Health Care Centre in Perth – Research Paper This research paper presents a case for alternatives to the Emergency Department in Perth that follow the lead of the Urgent Mental Health Care Centre (UMHCC) run by Neami National in South Australia. We use research and outcomes from existing examples of this model to demonstrate that a UMHCC would reduce costs, alleviate pressure on EDs, and provide high-quality, recovery-oriented support to consumers.
Deprescription Guidelines in Australia – this briefing paper examines the importance of the Maudsley Deprescription Guidelines for consumers, and calls for their use by Australian medical professionals. Please note that endorsing the Deprescription Guidelines does not mean CoMHWA endorses all guidelines and Approaches from Maudsley Hospital’
Click the buttons below to view previous years key publications: