Publications

Submission to consultation on a new Commonwealth individual disability advocacy program – Our team provided feedback to the Department of Health, Disability and Ageing on their draft plans and Program Policy Framework for a new Commonwealth individual disability advocacy program. We argued that although the intentions and proposed aims of the draft framework reflect what consumers have said they need, we feel that individual advocacy services need more resources and support to be able to carry out the goals of the plan. Our Systemic Team consulted closely with our Individual Advocacy team to ensure our submission reflected the needs and experiences of our advocates and the people they work alongside.

Submission to the NDIS Evidence Advisory Committee – We gave feedback to the Evidence Advisory Committee (EAC) reflecting what we’ve heard from our members about the importance of art and music therapy. We are concerned to hear that music and creative arts therapies might no longer be considered as NDIS supports, and we wanted to make sure that the EAC understands what a crucial role these supports can have in a person’s own definition of recovery.

Submission to the NDIS Annual Pricing Review 2025-26 – We gave feedback to the NDIS’ Annual Pricing Review, commenting mainly on how recently-set price caps have negatively impacted some NDIS Participants whose providers could not remain in the NDIS market due to these caps. We stated concerns that differentiated pricing will place participants in a difficult position where they must choose between supports that are high-quality, relevant and safe, and supports that they can access with the frequency or in the amount they need.

Submission to the NDIS: New Framework Planning – CoMHWA submitted feedback to the NDIS’ consultation on New Framework Planning. We relayed the concerns of participants who have felt that the approach, and the way it has been created with minimal consultation with people with disability, will leave participants out of the opportunity to be involved in the creation of plans that meet their needs. We also commented on the vague nature of the approach, which has resulted in both worry and concern from Participants about what the new framework planning process will look like, and a reduction in our capacity to provide meaningful feedback given the lack of specificity.

Submission to the NDIS Evidence Advisory Committee – We  gave feedback to the NDIS Evidence Advisory Committee on positive behaviour supports for adults, reflecting what we have heard from NDIS participants about their experiences with positive behaviour supports. We commented on some of the barriers that prevent positive behaviour support from enabling the kind of outcomes for participants that it was designed to achieve, notably around supporting the reduction and elimination of restrictive practices, and we called for action to promote quality supports and eliminate restrictive practices in the NDIS.

Submission to the NDIS into the Integrity of the NDIS– We gave feedback to the NDIS Joint Standing Committee on the Integrity of the NDIS, which sought to understand the nature, extent and impact of non-compliance in the NDIS and what was needed to address this and improve the integrity of the NDIS. CoMHWA’s submission reflected what participants tell us about experiences with different forms of non-compliance they encounter from providers, which causes distress, compromises their choice and control, and can undermine their ability to access supports they need. We discuss how policies to address non-compliance in the NDIS have typically taken the approach of increasing top-down regulatory authority and oversight and increasing penalties for non-compliance, and we argue that there is a need for future reform in this area to focus on increasing participant autonomy, choice, and control, involving participants as co-regulators, and co-design with participants

Submission to the Inquiry into Racism, Hate and Violence Directed at Aboriginal and Torres Strait Islander People: We gave feedback to the Joint Standing Committee on Aboriginal and Torres Strait Islander Affairs, which sought to understand the nature, extent and impact of racism, hate and violence directed at Aboriginal and Torres Strait Islander people and what was needed to eliminate this and reduce harm. CoMHWA’s submission represented what we heard from our members and consumers who are Aboriginal and/or Torres Strait Islander people about how systemic racism in the mental health system affects their social and emotional wellbeing and their ability to access and enjoy their human rights. We advocated for: systemic changes that give effect to the protections under the United Nations Declaration on the Rights of Indigenous Peoples and to the Gayaa Dhuwi (Strong Spirit) Declaration; mental health services that are codesigned with and accountable to Aboriginal and Torres Strait Islander people with lived experience; and culturally safe supports free from racism.

Submission to the Inquiry into the Guardianship and Administration System in WA: CoMHWA provided a submission to the WA Community Development and Justice Standing Committee calling for urgent, systemic reform of WA’s Guardianship and Administration System to better protect the human rights, autonomy, and dignity of mental health consumers and Aboriginal and Torres Strait Islander peoples. We highlight that it is essential that supported decision-making is central to these reforms, advocating for a transition away from substituted decision-making. We made recommendations aiming to transform the culture and operations of the State Administrative Tribunal, the Office of the Public Advocate, and the Public Trustee to ensure stronger accountability, oversight, advocacy access, and lived experience leadership across all levels.

Submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026: CoMHWA gave feedback to the Community Affairs Legislation Committee on the NDIS amendment bill informed by what we have heard from WA participants with psychosocial disability about the likely impacts of the bill’s key provisions. These include increased barriers to accessing the Scheme, fears from those who are on NDIS that they will be moved off the Scheme, fewer options for supports that meet needs, and large cuts to some categories of funding that will severely impact their ability to engage in their communities. We supported the recommendations of the National Mental Health Consumer Alliance (the Alliance) that they articulate in their submission, to which CoMHWA also provided input, in particular, protecting access to much needed supports (including social and community participation) and maintaining a rights-based framework for the NDIS.

Submission to the WA Suicide Prevention Framework – CoMHWA gave feedback to the Mental Health Commission’s draft of the State Suicide Prevention Framework, informed by our extensive consultation with our members across 9 workshops throughout the state earlier this year. While we were largely satisfied that the draft reflected what we heard from consumers in our consultations, we did emphasise areas that could be strengthened, including commitment to developing peer-led alternatives to Emergency Departments.

Submission to the Disability Discrimination Act Review – CoMHWA submitted a response to the Attorney General’s Office on the review of the Disability Discrimination Act 1992 (Cth). We argued for significant amendments to ensure that the Act protects the rights of people with mental health challenges and/or psychosocial disability to go about our lives free from discrimination.

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.

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.

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.

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.

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.

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.

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.

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.

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.

Submission to consultation on NDIS Act (Bill No 2) Quality and Safeguarding Measures – In this submission, we focus on providing feedback specifically informed by the experiences of participants accessing the scheme for supports with psychosocial disability. CoMHWA has provided feedback to the consultation in the form of responses to questions on a template provided by the consultation, and has prepared this document to present our responses to our members and the broader WA community, in order to provide more context for our positions on the proposed measures.

Feedback to Mental Health and Alcohol and Other Drugs Strategy 2025-2030 – CoMHWA is pleased to see acknowledgement in this Strategy of the need for rebalancing the system away from an emphasis on acute and hospital supports towards prevention and community-based supports, and hope that our feedback helps to enhance the focus on this across the whole document. This submission draws from our members’ feedback on the consultation paper and argues that more needs to be done to clarify how the Strategy will transform the system.

Select Committee on Cost of Living – This submission gives evidence to the Australian Government about the impact of the cost-of-living crisis on people with mental health changes. We had a very high number of members who wanted to share their views, experiences and ideas for change around the cost of living and we want to thank everyone who helped shape our submission. Our discussion shows that when people are not able to afford the basics (housing, healthcare, food), let alone entertainment and recreational activities that allow them to connect with family and friends, it can be much harder to be well. This isn’t news to anyone familiar with the social determinants of mental health, but it bears repeating while there are still policies in place that do not ensure equitable access to the things we need.

HaDSCO Review – The Health and Disability Services Complaints Office (HaDSCO) is reviewing their legislation for the first time in twenty years. In this submission, we share our members’ views on where HaDSCO services need improvement as well as where we think their powers and resources should be increased to hold health services accountable for intentionally or unintentionally causing harm or violating our members’ rights when they use health services. In particular, we emphasise the importance of involving Lived Experience expertise in HaDSCO policy and service delivery to better understand mental health challenges.

Western Australian Eating Disorder Framework – This submission offers feedback to the Mental Health Commission’s state Eating Disorder Strategy. Overall, the document aligns well with the key concerns raised by our members, particularly in its emphasis on early intervention, improving access to services, and the role of lived experience in program design. However, there are opportunities for improvement in areas like affordability of services, cultural responsiveness, and the availability of community-based supports. Enhancing attention to the needs of priority populations, such as Aboriginal people and gender-diverse individuals, would further strengthen the Framework’s impact.

Guardianship and Administration Act Review – In our preliminary submission to the review of the Guardianship and Administration Act 1990 (WA), we share our members’ and advocates’ experiences with Guardianship and Administration to underline specific issues that must be considered in the next stages of the review.

Feedback to the draft National Autism Strategy – We commend the National Autism Strategy for establishing a good starting place for considering what the Australian government can do to improve the lives of Autistic people. In this submission, we emphasise that more needs to be done to acknowledge that Autistic people have nuanced needs, strengths and desires, and that a one-size-fits-all strategy will ultimately not work effectively.

Feedback to the National Disability Insurance Scheme Amendment – This submission critiques the proposed legislation changes to the NDIS, which we believe signal a desire by the NDIA to divert people with psychosocial disability away from the NDIS. We argue that the changes must not apply new ‘one-size-fits-all’ Rules to NDIS Participants (current and prospective) in order to acknowledge that all individuals have unique support needs.

Remember PHaMs – This position paper has been developed to support of the “Bring Back PHaMs” grassroots campaign, which advocates for a new service, that takes up the many strengths and service philosophy of the PHaMs model, addressing the significant gaps left in the wake of funding moving to the NDIS.

Submission to the NDIS Regional Experience Inquiry – CoMHWA’s submission to the ‘NDIS participant experience in rural, regional and remote Australia’ Inquiry is founded upon the stories and experiences of our members, and aims to address the profound injustice faced by people accessing the NDIS and appropriate supports in Regional and Remote Australia.

 Feedback for the Department of Justice’s 2024-2029 Disability Access and Inclusion Plan – To ensure people with psychosocial disability are free from stigma, discrimination and are given respect and understanding in their encounters with the Department of Justice.

National Autism Strategy – This submission aims to convey the two-way relationship between mental health and secure housing and to argue for specific inclusions and priorities for secure and accessible housing/housing services for people with mental health challenges.

National Housing and Homlessness Plan – This submission aims to convey the two-way relationship between mental health and secure housing and argues for accessible housing for those with mental health challenges.

National Safety and Quality Mental Health Standards for Community Managed Organisations Guide for Service Providers – This Submission aims to ensure that safety and quality standards keep consumers at the centre of the project and to emphasise the importance of trauma-informed, human rights-based approaches.

MRFF and MREA Feedback – To optimise the government’s investment in health and medical research, the Department of Health and Aged Care and National Health and Medical Research Council (NHMRC) are undertaking national consultation to improve alignment and coordination between the Medical Research Future Fund (MRFF) and Medical Research Endowment Account (MREA).

Rental Crisis – Housing is a key social determinant of mental health – research shows that when people have access to secure housing and support to maintain that housing, their mental health outcomes are improved.

NDIS Review – CoMHWA welcomes the opportunity to make a submission to the NDIS Review on behalf of our members, many of whom are NDIS participants receiving support for psychosocial disability, to provide insight into how the NDIS is accessed, used and understood by people with psychosocial disability.

Submission: Feedback to the ADHD Inquiry – This papers purpose is to reduce and eliminate barriers to effective and holistic supports for ADHD.

Submission: Consistent Local Planning Schemes Consultation – To keep the status of alcohol and other drug rehabilitation centres classified as ‘community purpose’ land type in order to ensure smooth establishment and expansion of of AOD services.

Inquiry into Australia’s Human Rights Framework – CoMHWA supports the Australian Human Rights Commission’s call for a federal Human Rights Act that will offer people living in all states and territories protections of their rights.

Consultation Paper on Reforming WA Disability Legislation – Ensure that new disability legislation includes principles, safeguards, accessibility and services that meet the needs of and are relevant to people with mental health challenges.

Psychotropic Medicines in Cognitive Disability or Impairment Clinical Care Standard – CoMHWA urges the Australian Commission on Safety and Quality in Health Care to adopt and enforce supported decision-making principles in situations where medication will be given to a consumer.

Robodebt – This submission highlights the extreme distress experienced by consumers of mental health who were affected by this unlawful and discriminatory debt recovery scheme.

Stigma and Discrimination Reduction Strategy – This submission represents CoMHWA members’ views on National efforts to address stigma and discrimination of people with mental health issues.

2023 Briefings

Evaluation Report of the Alternatives to Suicide Program – This briefing paper outlines the findings of an evaluative report about the guiding principles, structure and future development of the Alt2Su program.

WHO Reform – In order to develop a standardized global initiative to promote the ‘meaningful engagement’ between government, service providers and consumers, the WHO proposed to use a collaborative approach of co-design to receive feedback on The Framework.

Unlawful Detention – This briefing papers provides an overview of recent incidents where hospital staff have facilitated the unlawful practice of detaining people in hospital settings.

Proposing Regulations to Mental Health Apps – This briefing paper offers an understanding of the lack of regulation in Australia for mental health apps.

Pharmacy Reform – In 2018 the Pharmaceutical Benefits Advisory Committee (PBAC) proposed that the
Pharmaceutical Benefits Scheme (PBS) be amended to allow for a select range of medicines to be prescribed in 60-day increments, requiring a new prescription every 12 months.

Scriptcheck – While WA has long had monitoring systems for some prescribed medicines, the development of ScriptCheckWA raises serious digital privacy concerns for mental health consumers

Public Trustee – The exploitation of those under the care of the Public Trustee by the procedures of this institution.

Group Services Closure – CoMHWA members who are users of group services through Neami, Grow or Richmond Wellbeing have contacted us, either through our members’ survey or through reaching out individually, to underline the impact the defunding of these services will have on their recovery journeys.

Long Stay Patients in Hospital – To ensure that people are not kept in hospital past the point where they are medically ready to be discharged and that they are discharged with appropriate support in the community

CLMIA/CLMI Bill Reforms and Update – The Criminal Law: Mentally Impaired Accused 1996 (CLMIA) Bill denies people due process, natural justice, and human rights and compromises public safety by creating barriers to people accessing vital supports.

Eliminating Restrictive Practices –  The dehumanising effect of restrictive practices on consumers is a major concern for many CoMHWA members, and the lived experience of members consulted for feedback highlighted how these practices led to fear, anxiety and despair for those that are subjected to them.

Better Access Reforms – Evaluation of the initiative to improve the Medicare Benefits Scheme
to ensure more equitable access to psychosocial supports