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Compliance7 min read

SIL 0138 claim changes: An SDA provider boundary checklist

From 1 July 2026, Supported Independent Living providers move to a new SIL claim pathway using registration group and support code 0138. The change is aimed at SIL providers, but SDA teams should still pay attention. Many SDA homes operate beside SIL providers, and some organisations provide both housing and daily supports. When the support provider's registration, invoice pathway or participant relationship changes, the SDA record needs to stay clear, auditable and separate.

What changed for SIL from 1 July 2026

The NDIS has announced that SIL providers must use the new code 0138 - Assistance with Supported Independent Living for supports delivered from 1 July 2026. Supports delivered before that date continue to use the previous 0115 code.

The NDIA has also told plan managers that, from 1 July 2026, invoices for SIL delivered after that date should include the new 0138 support items. Plan managers may only pay those invoices where the provider is registered under 0138, has applied under 0138, or is an existing unregistered provider that was delivering SIL before 1 July 2026. Unregistered SIL providers that do not apply by 1 October 2026 can only claim for services up to 30 September 2026.

This is not an SDA pricing change and it does not replace SDA dwelling enrolment or SDA claiming controls. The NDIS Commission states that there are no changes to registration requirements for SDA providers. The operational risk is that shared-home teams may blur SIL and SDA records when they are trying to solve registration, invoice or participant-transition issues quickly.

Why SDA teams need a boundary record

NDIS participant guidance describes SDA as the housing itself and SIL as funded support workers who help with day-to-day tasks in the home. Some participants have both supports, but the funding purpose, provider obligations, agreements and claim evidence are different.

The NDIS Commission's supported accommodation work has also highlighted that the interaction of SIL and SDA arrangements can affect people's ability to make changes to their living arrangements. It is exploring legal and practical separation of SIL and SDA as part of supported accommodation reform.

For an SDA provider, the practical response is not to redesign the whole operating model overnight. It is to make sure the housing record can prove what belongs to SDA, what belongs to SIL, who is responsible for each action, and how participant choice and tenancy security were protected.

A practical SDA and SIL boundary checklist

Use the SIL 0138 transition as a trigger to review shared-home operating records. The useful test is whether a new manager, auditor or owner-reporting lead can understand the relationship without reading private support notes or reconstructing the history from emails.

Separate the SDA agreement from SIL support records

Keep the SDA service agreement, occupancy terms, dwelling enrolment details, RRC records and SDA claim evidence separate from SIL rosters, SIL invoices and daily support documentation. Where the same organisation provides both supports, the SDA Practice Standards expect separate service agreements for SDA and other NDIS supports.

Maintain a SIL partner status register

Record each SIL provider connected to a dwelling, their 0138 registration or application status where relevant, evidence date, transition risk, contact owner and next review date. This is not a substitute for the SIL provider's own compliance work, but it helps the SDA team anticipate handover and participant communication risks.

Document conflict and choice controls

Where SDA and SIL are connected through ownership, referral pathways, shared staff or a preferred-provider arrangement, keep a conflict-of-interest note that explains how participant choice is protected and how housing rights are not tied to a support-provider decision.

Keep claim pathways distinct

SDA claims should continue to reconcile against SDA support items, dwelling enrolment, participant eligibility, service dates, RRC treatment and payment outcomes. SIL invoices and 0138 payment issues should not be posted into SDA income or owner statements as though they were property revenue.

Create a shared-home handover protocol

If a SIL provider exits, changes registration status, changes claim process or changes support model, record who tells participants, nominees, support coordinators, plan managers, the SDA tenancy team and owners. The record should say what changed, what did not change, and which actions sit with the SIL provider versus the SDA provider.

When one organisation provides both SDA and SIL

Dual-provider models need especially clean records. The SDA supplementary module expects providers to proactively manage perceived or actual conflicts of interest, explain the distinction between SDA and other NDIS supports, and uphold housing rights regardless of a participant's decision about other supports in the dwelling.

That means the operational file should avoid mixed language such as tenant must use our SIL team. It should show the SDA agreement, any SIL agreement, participant communication, decision support, complaint pathway, incident handoff process and any internal separation of duties.

The same file should also separate financial reporting. SDA income, RRC handling, vacancy evidence and owner distributions are property and accommodation records. SIL claim status, 0138 invoice acceptance, plan manager rejection and support worker costs belong in the SIL operating record.

Provider-to-provider handovers

If the SIL provider is external, the SDA team still needs enough structure to manage participant experience and property risk. A useful handover record includes current SIL provider, registration or application evidence date, key contacts, participant communication status, support model dependencies, incident and complaint pathways, emergency contacts, move-in or move-out status, and any owner-reporting implication.

Be careful with privacy. Owner reporting should explain property-level operational status without exposing participant-identifying SIL information. A useful owner update might say that a daily-support provider transition is underway and that SDA claiming remains claim-ready, paused or under review. It should not copy private support notes into an owner statement.

SDA teams should also keep an exception queue for unclear cases: no 0138 evidence received, participant wants to change SIL provider, plan manager invoice rejected, support provider exit notice received, conflict disclosure required, tenancy risk identified or owner communication pending.

How StepFree fits the workflow

StepFree SDA should help providers keep the housing, participant, claim, vacancy, RRC, owner-reporting and partner-status records connected without merging SDA and SIL responsibilities.

For providers managing many homes, the value is in repeatable controls: one dwelling record, one participant occupancy record, one SDA claim record, one SIL partner status note, one exception queue and one owner-safe reporting view. That gives operations, finance and leadership a shared picture while preserving the boundaries that matter for compliance and trust.

Conclusion

The SIL 0138 claim change is not an SDA claim change, but it is a useful moment for SDA providers to tighten shared-home records. Clear agreement separation, partner status tracking, conflict controls, distinct claim pathways, handover protocols and owner-safe reporting help protect participant choice while keeping SDA operations auditable.

StepFree SDA can help providers manage SDA claims, participant occupancy, RRC records, SIL partner status, shared-home exceptions and owner reporting from one controlled operating workflow.