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.

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.

The Impact of NDIS Changes on People with Psychosocial Disability – In this paper, we explore the impacts of recent changes in the National Disability Insurance Scheme (NDIS) on people with psychosocial disability, who have encountered reduced ability to access the Scheme and increased restrictions on their access to the supports they need, and who as a consequence have experienced increased concerns about their future in the NDIS. We state CoMHWA’s position that it is essential that people with psychosocial disability are able to continue to access the NDIS, and we advocate for meaningful collaboration and co-design with participants with psychosocial disability when making decisions about and planning potential changes to the Scheme.

2026 Submissions

January

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.

February 

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.

March

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

Click the buttons below to view previous years key publications:

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’

Supported Decision Making in Mental Health – A Literature Review – In 2022, CoMHWA was asked to provide a literature review about Supported Decision Making as part of the Mental Health Commission’s review of the Mental Health Act 2014 (WA). In this document, we explore arguments made for the value of supported decision-making as a framework to maximising an individual’s involvement in decisions made about their lives.