Submission to the NDIS Access Changes Consultation
September 2026
Contact details
For more information, please contact:
Karen Dimmock CEO, ACD
e: karend@acd.org.au
Helen Nys CEO, Kiind
e: helen.nys@kiind.com.au
Stacey Touma CEO, Belongside Families
e: stacey@belongsidefamilies.org.au
Recommendations
Guiding principles
Recommendation 1: Add an access principle recognising childhood as a distinct developmental stage, characterised by rapid development and changing functional capacity.
Access decision-making process design
Recommendation 2: Ensure access decisions are based on an individual’s overall functional capacity, taking account of the combined impact of multiple disabilities and health conditions.
Recommendation 3: Provide streamlined NDIS access to children with manifest impairments associated with the highest and lifelong support needs. For children with these impairments, continued access to the NDIS should not require repeated re-demonstration of eligibility.
Recommendation 4: Ensure family circumstances inform access decisions where a child is close to the eligibility threshold, particularly where families are supporting multiple children with disability and experiencing significant cumulative support demands.
Recommendation 5: Clearly communicate how eligibility and access decisions are made, and the reasons for those decisions.
Recommendation 6: Provide clear reassessment and reapplication pathways for families of children close to the access threshold where a child does not initially meet NDIS access requirements but may become eligible as their functional capacity and support needs change over time.
Recommendation 7: Build workforce capability to strengthen professionals’ understanding of disability support systems, changes to the NDIS, and referral pathways for children and families, supporting timely information, advice and referrals and reducing reliance on “wait and see” approaches that can delay access to support.
Introduction
The Child and Family Disability Alliance (CAFDA) is a national partnership of not-for-profit family-led organisations: ACD, Kiind and Belongside Families.
Together, we support more than 30,000 families and carers raising children with all kinds of disability and developmental delay across Australia.
Our shared vision is to empower parents and caregivers with the knowledge, skills and connections they need so their families and children can thrive. We work by building the capacity and wellbeing of parents and carers through our well established and proven model providing information, skills building and peer support.
CAFDA welcomes the opportunity to contribute to the consultation on NDIS access change. Our submission focuses on ensuring that the experiences and needs of children with disability and their families are reflected in the design and delivery of the proposed reforms to NDIS access and eligibility.
Guiding principles
Recognise childhood as a unique stage of life
Recommendation 1: Add an access principle recognising childhood as a distinct developmental stage, characterised by rapid development and changing functional capacity.
Childhood is a distinct stage of life, marked by rapid developmental, social and emotional growth. This should be reflected in the principles of NDIS access, ensuring service design is not solely adult-orientated.
Access decision-making process design
Access decisions should reflect the combined impact of multiple disabilities and health conditions
Recommendation 2: Ensure access decisions are based on an individual’s overall functional capacity, taking account of the combined impact of multiple disabilities and health conditions.
An individual’s functional capacity should be understood in the context of the whole person, rather than being limited to the impacts of a specific disability or impairment. This is particularly important for children, whose overall functional capacity is often shaped by the interaction of multiple disabilities and health conditions. Focusing on a single impairment may not accurately reflect the combined impact of these factors on their everyday functioning and support needs.
Streamlined and ongoing NDIS access for children with the highest support needs
Recommendation 3: Provide streamlined NDIS access to children with manifest impairments associated with the highest and lifelong support needs. For children with these impairments, continued access to the NDIS should not require repeated re-demonstration of eligibility.
For children who are existing participants with impairments associated with the highest and lifelong support needs, continued access to the NDIS should not require repeated re-demonstration of eligibility. This would reduce unnecessary stress and burden for families, while avoiding inefficient use of Scheme resources. Processes to expedite support already exist in other Commonwealth systems, such as the Disability Support Pension, which recognises a range of conditions for manifest eligibility.
The access process should also recognise conditions that are known to be associated with lifelong significant support needs, even where these needs are not yet fully apparent through a functional assessment in infancy or early childhood. Families should not have to wait for the functional impacts of a condition to become more apparent before they can access support. Access decisions should be able to draw on clinical evidence about the likely trajectory of a condition, rather than relying solely on a child’s functional presentation at a single point in time.
Family circumstances should inform access decisions near the eligibility threshold
Recommendation 4: Ensure family circumstances inform access decisions where a child is close to the eligibility threshold, particularly where families are supporting multiple children with disability and experiencing significant cumulative support demands.
How well a child manages day-to-day life is shaped, in part, by the support available to them. While the access process seeks to assess functional capacity “in a context that excludes, as far as possible, the impact of the person’s environmental and personal circumstances”, a child’s needs cannot be fully understood in isolation from their family context and the support their family provides.
Caring for a child with disability often requires greater frequency and intensity of parental support than caring for a child without disability. For families supporting multiple children with disability, the combined caring demands can be significant. Even where each child’s needs are considered ‘moderate’ when assessed individually, together they can require a high level of care from the family.
CAFDA is concerned that these families may be disadvantaged by an access process that does not consider family circumstances. Under a tighter access process, children who previously qualified may no longer do so, even though their disability and the level of disability-related support required within their household have not changed.
To support person-centred and equitable access, family circumstances, particularly cumulative caring load and capacity, should be considered when determining access for children who are close to, but do not meet, functional capacity access thresholds.
Ensure transparent access decisions and clear reassessment pathways
Recommendation 5: Clearly communicate how eligibility and access decisions are made, and the reasons for those decisions.
Recommendation 6: Provide clear reassessment and reapplication pathways for families of children close to the access threshold where a child does not initially meet NDIS access requirements but may become eligible as their functional capacity and support needs change over time.
While the new access process will remove current diagnostic lists, we note that these lists at least provided families and the public with a transparent basis for understanding who could access the Scheme. The new access process should not reduce transparency and should clearly communicate how eligibility and access decisions will be made.
Some children may not meet the access threshold when assessed, but may become eligible within a relatively short period as their functional capacity and support needs change over time. For these families, there should be clear information about reassessment and reapplication pathways, including when and how eligibility can be reconsidered, to help avoid extended gaps in access to necessary supports.
Build workforce capability to support timely referrals for children and families
Recommendation 7: Build workforce capability to strengthen professionals’ understanding of disability support systems, changes to the NDIS, and referral pathways for children and families, supporting timely information, advice and referrals and reducing reliance on “wait and see” approaches that can delay access to support.
For children and families, access to disability support often depends on professionals recognising developmental concerns and disability, providing accurate information, and connecting families with the right systems, including the NDIS. Families consistently report receiving inconsistent advice about disability, available supports and referral pathways, leaving them to navigate complex systems on their own. This includes advice from professionals who are often a family’s first point of contact, such as paediatricians, maternal and child health nurses, and GPs.
We also hear from families about “wait and see” approaches when concerns about a child’s development or disability are first raised. While monitoring development may be appropriate in some circumstances, delays in providing information, advice or referrals can prevent children and families from accessing support at an early stage.