ACD

Submission: NDIS new framework planning

March 2026

Background

ACD is the Victorian advocacy service for children with disability and their families. We are a not-for-profit organisation led by, and for, families of children with disability.

Our vision is an inclusive community where children with disability and their families thrive.

ACD welcomes the opportunity to contribute to the consultation on the new NDIS planning framework. However, key elements remain unclear, including how budgets will be determined. Continued, meaningful consultation with the community will be essential to ensure reforms are implemented effectively and without unintended consequences.

For more information contact

Karen Dimmock CEO

karend@acd.org.au

0448 912 786

ACD acknowledges the Traditional Owners of this land. We recognise their continuing connection to land, waters and community. We pay respects to Elders past and present.

Executive summary

ACD welcomes the opportunity to contribute to consultation on the proposed new NDIS framework planning. This reform represents a significant change in how participants’ support needs are assessed and funded. To ensure fairness, accuracy and confidence in the system, strong safeguards, transparency and participant rights must be maintained. Participants must retain the right to seek internal and external review of decisions, including the ability to challenge specific planning and funding outcomes and provide additional evidence. Limiting review rights would weaken accountability and risk decisions that do not accurately reflect individual needs.

Assessments must be youth responsive and draw on multiple sources of evidence, including the young person, their family, trusted supporters and relevant professionals, to ensure support needs are fully understood. Assessor capability will be critical, and NDIA assessors must have appropriate disability expertise, alongside skills in inclusive communication, trauma-informed and child safety.

The assessment process must also be accessible and flexible, allowing breaks, multiple sessions, accessible preparation materials and appropriate communication supports. Flexibility is particularly important during adolescence, when support needs can change rapidly. Participants must be able to access timely reassessment or plan variations when circumstances change and extend plans where supports remain effective.

Finally, any changes to NDIS planning processes for children aged 15 and under must be developed and implemented with a clear child safety and family-centred lens, ensuring planning processes are safe, developmentally appropriate and responsive to family context.

Recommendations

A fair process

Retain participants’ rights to seek internal and external review of NDIS decisions, including the ability to challenge specific planning and funding outcomes and provide additional evidence where needed.
Ensure the new framework provides sufficient flexibility for timely reassessments or plan variations when a young person’s circumstances or support needs change.
Allow plan rollovers where supports remain appropriate and effective, particularly to ensure continuity during transition periods and avoid unnecessary reassessment burden.

Youth responsive

Ensure support needs assessments draw on multiple sources of evidence, including the young person, their family members, trusted supporters and relevant professionals, while respecting the young person’s will and preferences and keeping their voice central.
Embed supported decision-making practices that enable young people to understand decisions, express their will and preferences, and maximise their participation in decision-making processes.
Require assessment processes to allow breaks and completion over multiple sessions, provide accessible preparation materials and communication supports, and include structured questioning that captures how tasks are completed in daily life and the supports required.
Require NDIA assessors to meet minimum qualification and training standards, including demonstrated expertise in disability, accessible and inclusive communication, trauma-informed practice and youth-responsive approaches, to ensure assessments are safe, inclusive and accurately reflect the young person’s needs and circumstances.

Child safe approach

Noting the new planning framework includes children under the age of 18, embed a child-safe approach within the framework, including mandatory training and clear protocols to ensure NDIA assessors can identify and respond to safeguarding risks, recognise when nominees may not be acting in the young person’s best interests, and prioritise the young person’s safety and rights.
Ensure any changes to NDIS planning processes for children aged 15 and under are developed with a clear child safety and family centred lens.

A planning process that works for young people and families

Maintaining review safeguards and procedural fairness in the new assessment framework

Recommendation

Retain participants’ rights to seek internal and external review of NDIS decisions, including the ability to challenge specific planning and funding outcomes and provide additional evidence where needed.

Strong review rights and are fundamental safeguards within the NDIS. Participants must continue to have access to both internal review within the NDIA and independent external review by the Administrative Review Tribunal, with the ability to challenge aspects of their plan, including conditions of how its spent.

Review and plan variation processes must allow reconsideration of the merits of a decision, not solely whether correct process was followed. Participants should be able to provide additional evidence, including reports from treating professionals and other relevant sources, to ensure decisions accurately reflect their individual circumstances.

These safeguards are essential to maintaining transparency, accountability and procedural fairness within the planning framework. Without meaningful review pathways, families may be left with plans that do not adequately reflect their child’s needs and limited options to seek correction.

Equally, transparency is critical. Families must be able to understand how assessment findings translate into funding outcomes, receive clear reasons for decisions, and be provided with a draft plan with adequate time to review it and seek advice where required, including advocacy support. This is not only essential to procedural fairness, but also reduces strain on families and the review system by identifying and resolving errors or omissions early.

A process that recognises life transitions during adolescence and early adulthood

Recommendations

Ensure the new framework provides sufficient flexibility for timely reassessments or plan variations when a young person’s circumstances or support needs change.

Allow plan rollovers where supports remain appropriate and effective, particularly to ensure continuity during transition periods and avoid unnecessary reassessment burden.

Adolescence and early adulthood involve significant life transitions that can substantially change a young person’s circumstances and support needs. For many, this includes finishing school, where they may previously have been engaged in structured activities for 30 to 40 hours per week. Support needs during these transitions can shift rapidly and are often difficult to predict in advance.

Like all young people, adolescents with disability also experience changing preferences for social and community participation, with an increasing desire for independence from their family. Adolescence is also associated with significant physical and hormonal changes, which can affect emotional regulation, behaviour and support needs. These changes can emerge quickly and may require timely adjustments to supports.

It is important that the new planning framework recognises these developmental, emotional and social changes, and supports young people with disability to participate in their communities with dignity and autonomy. The assessment and planning process must be sufficiently flexible, including access to timely plan variations, to respond to changing circumstances and support needs, rather than locking participants into arrangements that no longer reflect their situation.

Equally, where a plan is working well and circumstances remain stable, families should be able to request plan rollovers without undergoing a full reassessment. This would reduce unnecessary administrative burden while maintaining continuity and stability for the young person.

Including families, carers and trusted supporters

Recommendations

Ensure support needs assessments draw on multiple sources of evidence, including the young person, their family members, trusted supporters and relevant professionals, while respecting the young person’s will and preferences and keeping their voice central.

Embed supported decision-making practices that enable young people to understand decisions, express their will and preferences, and maximise their participation in decision-making processes.

Young people may not fully recognise the extent of support provided by families or support workers and may underestimate their needs during support needs assessments. They may also feel uncomfortable with an unfamiliar assessor, find aspects of the questioning confronting, or mask their difficulties and rush through responses to finish the assessment. This creates a risk that assessments do not accurately capture their full support needs.

ACD understands that participants may have a family member, nominee or advocate attend the assessment, but there is limited detail on how supporters may contribute and how their input will be incorporated. Assessment processes must ensure that input from both the young person and those who know them well is actively sought and meaningfully considered.

Assessments must draw on multiple sources of information, including the young person, their family members and other trusted supporters, as well as relevant professional evidence. This is essential to ensure support needs are fully understood, particularly where young people may understate their needs or may not fully recognise the extent of support they receive. At the same time, the assessment process must respect the young person’s will and preferences, ensuring their voice remains central and is complemented, not replaced, by additional perspectives.

In practice, this should include:

Actively inviting parents, carers and support workers to contribute context and clarify what support is required in daily life
Providing opportunities for families to share information privately about the support they provide and what is needed to continue caring safely and sustainably
Allowing allied health professionals to submit reports and other supporting evidence to inform the assessment and provide a holistic understanding of the young person’s functional needs (beyond evidence required for stated supports).

An accessible, safe and flexible assessment process

Recommendation

Require assessment processes to allow breaks and completion over multiple sessions, provide accessible preparation materials and communication supports, and include structured questioning that captures how tasks are completed in daily life and the supports required.

The proposed three-hour assessment period will be too long for many young people. Participants and their families should have the option to take breaks or complete the assessment over multiple sessions. The process must make it easy to pause, reschedule or continue at another time if a young person becomes overwhelmed or needs time to regulate.

To ensure participants feel at ease and can provide accurate information, they should be able to complete the assessment in their preferred format, including face-to-face, virtually or other remote options.

The questions may be confronting and difficult to answer on the spot. To support accessible participation, clear information about what to expect, including the types of questions that will be asked, should be provided in advance and in a range of accessible formats such as visual supports, Easy Read, social stories and translated resources. This will allow participants to prepare emotionally and practically.

The interview process must also include readily available communication supports, including plain English materials, interpreters, accessible formats and AAC supports.

To support accurate and meaningful participation, the line of questioning should also:

Allow questions to be clarified or reworded so the young person and their family can provide accurate responses
Focus on how tasks are completed in daily life, rather than asking only whether they can be done
Avoid ambiguous or overly complex questions that may cause confusion
Explore practical daily living tasks in detail, rather than relying solely on broad or headline questions
Include prompts about what supports are required, not just what the young person can do independently.

Skilled, disability-informed assessors

Recommendation

Require NDIA assessors to meet minimum qualification and training standards, including demonstrated expertise in disability, accessible and inclusive communication, trauma-informed practice and youth-responsive approaches, to ensure assessments are safe, inclusive and accurately reflect the young person’s needs and circumstances.

Families are concerned that the competence of assessors will significantly influence assessment outcomes, particularly given the substantial weight placed on the I-CAN assessment within the new framework. Assessors must have appropriate qualifications and demonstrated expertise in disability, including a strong understanding of a wide range of disabilities and health conditions, as well as expertise in accessible and inclusive communication and trauma-informed practice. This is essential to ensure the assessment process is safe, inclusive and accurately reflects the young person’s needs, strengths and circumstances.

Embedding child safety in the assessment framework

Recommendation

Embed a child-safe approach within the framework, including mandatory training and clear protocols to ensure NDIA assessors can identify and respond to safeguarding risks, recognise when nominees may not be acting in the young person’s best interests, and prioritise the young person’s safety and rights.

Having a nominated family member present during the assessment process can be an important safeguard, helping ensure the assessor gains a holistic understanding of the young person’s support needs, daily life and preferences. However, in some circumstances this may also present risks. Young people in precarious out-of-home care arrangements, experiencing family violence, or living in unsafe or unstable environments may not have a legal guardian or family member who is able or willing to act in their best interests. In some cases, nominees may minimise, deny or misrepresent the young person’s needs.

In these complex situations, the integrity and safety of the process relies heavily on the assessor’s capability. Assessors must be appropriately trained in child-safe practice, including identifying and responding to safeguarding risks, engaging child and family services or other professionals where needed, and seeking input from trusted adults or advocates to ensure the young person’s voice, views and needs are heard and prioritised.

There is also concern that the new assessment process may be primarily designed with adults in mind, given it applies from age 16. Without explicit safeguards, the distinct developmental needs, rights and vulnerabilities of young people aged 16–17 risk being overlooked. The framework must clearly recognise young people as a distinct cohort and embed child-centred safeguards, including age-appropriate engagement, child safety protocols, and mechanisms to ensure their views and best interests are central to decision-making. In practice, this may look like a specialist assessors designated to young people’s assessments.

Design principles for planning reform affecting children

Recommendation

Ensure any changes to NDIS planning processes for children aged 15 and under are developed and implemented with a clear focus on child safety and family-centred lens.

ACD understands that the proposed new framework currently applies to NDIS participants aged 16 years and older, and it remains unclear whether, or how, planning processes may change for younger participants. Any future changes affecting children should be developed with a clear focus on child safety and family-centred lens, and informed by consultation and co-design with families and sector experts. For children in the early childhood period, reforms should be designed in alignment with the National Best Practice Framework for Early Childhood Intervention to maintain evidence-based practice and avoid fragmentation across the system.