Joint Submission on proposed NDIS access changes
Submission to the Department of Health, Disability and Ageing
October 2026
About
The Federation of Ethnic Communities’ Councils of Australia (FECCA)
The Federation of Ethnic Communities’ Councils of Australia (FECCA) is the national peak body representing people from culturally and linguistically diverse (CALD) communities and their organisations across Australia.
Through the membership of state, territory and regional ethnic communities’ councils and their networks, FECCA represents the interests of more than 1,500 multicultural community organisations nationwide. FECCA provides a collective national voice on issues affecting Australia’s multicultural communities, including migration, settlement, workforce participation, skills recognition, human rights, social cohesion and equity.
The Australian Multicultural Health Collaborative (the Collaborative) is the national multicultural health peak body.
Vision Statement: In a truly multicultural Australia, our health and social care system is committed to health equity, and works proactively towards sustained improvement in the physical, mental and spiritual health and wellbeing of our multicultural communities.
The Collaborative
The Collaborative is an initiative of the FECCA. We provide a national voice, leadership and advice on policy, research, data, and practice to improve access and equity, address systemic racism, and achieve better health and wellbeing outcomes for Australians from multicultural backgrounds. The Collaborative is representative, and membership based. Members include consumers and carers; health services and wellbeing/social care services; practitioners; and researchers. The Collaborative also welcomes as affiliates other national health peak organisations.
Introduction
FECCA and the Collaborative (jointly as ‘FECCA’) welcome the opportunity to comment on the proposed NDIS access process. We support clearer and more consistent decisions based on the functional impact of disability. The test of this reform, however, will be whether people with similar needs can navigate the process and receive comparable decisions, regardless of their language, cultural background or ability to obtain specialist reports.
Our submission below outlines advice on principles, assessment design, evidence and referrals and we acknowledge that final eligibility thresholds and transition arrangements will require further consultation. Our recommendations address the design choices now before the Technical Advisory Group and the Department, while identifying safeguards that will need to carry through to implementation.
1. Make equity a practical requirement of the guiding principles
The draft principles refer to cultural safety and accessible processes. They should also expressly require funded language access at every stage: initial information, application, functional assessment, evidence gathering, decision letters and review. Applicants should be told how to request a qualified interpreter without cost. Information should be available in appropriate languages and accessible formats, and assessors should be trained to work through interpreters. Family members should not be expected to
interpret sensitive disability or health information. People should be able to involve a supporter of their choice while retaining control over their own account and decisions.
FECCA have recently identified linguistic, cultural, digital and navigation barriers as practical obstacles to participation for multicultural people with disability. The same barriers can affect whether an access application is made, what evidence is gathered and how an assessment is understood.1
2. Test the assessment for fairness before setting thresholds
A standardised assessment can improve consistency, but an instrument used in English or without appropriate communication support may measure language proficiency or familiarity with the assessment task as well as disability-related capacity. Before any tool or threshold is adopted, the Department should publish evidence that it is reliable and valid across languages, cultural contexts, impairment types, ages and locations. Testing should involve multicultural people with disability, including those who use interpreters, and should examine whether the same needs produce comparable outcomes.
The paper defines functional capacity by reference to activities in a standardised environment, while the proposed reform is intended to understand the impact on day-to-day life. Assessment guidance should explain how both are considered. It should record fluctuating needs, communication methods, aids, informal support and the person’s own account of what happens at home and in the community. A score should not displace relevant clinical and lived-experience evidence without a clear explanation. Applicants should receive the assessment and reasons in a form they can understand, with an accessible route to correct errors and seek review.2
3. Do not make evidence requirements depend on resources
The process should accept relevant existing evidence from GPs, allied health professionals, hospitals and other services, alongside the person’s account and observations from people who know their day-to-day support needs. It should give clear guidance on what is genuinely necessary for each access criterion. Where a further report or assessment is essential, the process should help arrange and fund it rather than assuming an applicant can obtain and pay for it. Evidence already supplied should be reused so people do not have to repeat their story across services.
Guidance on permanence and appropriate treatment should distinguish a treatment’s theoretical availability from whether it is clinically suitable and practically accessible to the person. Waiting times, location, language support and other barriers may affect whether someone can obtain care. A person should not be disadvantaged because they could not access a service, and decisions should explain what treatment was considered, why it was considered appropriate and its expected effect on the impairment. This should respect informed decisions about treatment.3
4. Make referrals to other supports an effective handover
When an applicant does not meet NDIS access requirements, a referral should identify a service that is actually available and appropriate to their needs, explain how to reach it, and offer help to make contact. A general direction to mainstream or Foundational Supports is insufficient if the service has a long wait, cannot provide language access or is not yet operating locally. The Department should track whether people connect with a service after referral and use failed referrals to identify gaps between systems. This matters particularly as Thriving Kids is due to roll out progressively through January 2028, when the new NDIS access process begins.4
5. Publish equity evidence and co-design the next stage
Before implementation, the Department should publish equity impact modelling and the results of testing with diverse applicants. It should then report, with appropriate privacy protections, application and refusal rates, reasons for decisions, time taken, interpreter use, review outcomes and connection to alternative supports. Analysis should include language needs and other relevant demographic characteristics, as well as disability type, age and location. Data about current participants alone will not show who never reaches the Scheme. FECCA has already raised the absence of published disaggregated modelling of the reforms.5
1 FECCA and AMHC, Joint submission on the Inclusive Communities Fund (2026). 2 Department of Health, Disability and Ageing, Consultation paper on NDIS access changes (2026); Final changes to the NDIS Amendment Bill (August 2026). 3 Department, Consultation paper 4 Department, Consultation paper 5 FECCA, Federal Budget 2026-27 analysis (2026).
The next consultations on thresholds, transition and implementation should include multicultural people with disability and their representative organisations, including the National Ethnic Disability Alliance, as paid contributors to design and testing. Existing participants will be reassessed over a three-year transition from January 2028; they will need clear advance information, language support and an opportunity to provide relevant evidence before any access decision is made.6
Conclusion
An access pathway is fair only if it assesses disability and support needs without allowing a person’s ability to navigate bureaucracy to decide the outcome. These changes will shape who enters the NDIS and what happens to those who do not. English proficiency, the cost of obtaining evidence and barriers to treatment must not be mistaken for a lack of disability or need. For someone refused access, a referral must lead to support they can actually use.
FECCA ask the Department to build funded language support, proportionate evidence requirements, culturally safe assessment and effective referrals into the final design. These safeguards should be tested with multicultural people with disability before thresholds are finalised, applied throughout the reassessment of existing participants, and measured through public reporting that can reveal and correct inequities.
We welcome the opportunity to work with the Department and representative organisations to test the information, assessment and referral pathways. This reform should be judged by the fairness of its decisions and the support people can actually reach.
FECCA would welcome the opportunity to help test information, assessment and referral pathways with multicultural communities as the detailed design develops. We also offer our expertise in an advisory capacity to the Technical Advisory Group, should it require representation and insights from a multicultural perpsective.
6 Department, Consultation paper
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