Creating an autism inclusive Australia.

BUILDING A FRAMEWORK FOR BETTER DECISIONS, SUPPORTS AND OUTCOMES.

AMAZE SUBMISSION:

New Framework Planning and NDIS Supports consultation.

14 OCTOBER 2026

Acknowledgement of Country

Amaze respectfully acknowledges the Wurundjeri Woi Wurrung peoples of the Kulin Nation as the Traditional Custodians of the land on which we work.

We pay respect to their Elders past and present and reflect on the continuing connection with Country and community.

Recognising our work provides services to the Autistic community in all corners of the land now referred to as Australia, we extend this acknowledgement to all Aboriginal and Torres Strait Islander peoples across this continent.

About Amaze
Executive Summary
Key messages and recommendations
Introduction
Amaze responses to consultation questions
1. Support Needs Assessment rules
2. Budget method rules
3. Plan variation and reassessment rules
4. NDIS supports rules
5. General questions

About Amaze

Amaze was established in 1967 by a group of parents who faced challenges in accessing resources for autism. For nearly 60 years, Amaze has provided support to Autistic people and their families. While based in Victoria, its services extend across Australia. Amaze is dedicated to increasing autism awareness within the community, influencing policy change, and delivering independent, credible information and resources.

In 2021, Autism Connect successfully expanded from a small, Victoria-based autism information service to a national autism information service, maintaining high quality and satisfaction levels among individuals, families, and caregivers throughout Australia. To date, more than 50,000 cases have been managed through this service. We were excited to commence delivery of the national Thriving Kids helpline and information service on 1 October 2026.

Amaze also partners with various organizations to create inclusive environments that support Autistic people. The organisation helps workplaces move beyond mere awareness to meaningful action by offering practical training, professional development programs, and advisory services that promote cultural safety, accessibility, and inclusion.

Its professional development and training offerings cater to participants at any stage of learning and are delivered flexibly across Australia. The programs are designed in partnership with individuals with lived experience, including opportunities for meaningful discussion, ongoing reflection, and real-world application. Additionally, Amaze provides advisory and consulting services to people leaders, HR professionals, and Diversity & Inclusion teams, assisting them in embedding inclusive practices throughout the employee lifecycle. These services support organizations in creating sustainable change and building more inclusive workplaces for Autistic employees.

Amaze vision: An Australia that embraces Autistic people and their families living their best lives.

Amaze mission: To create positive change for Autistic people and their families at all life stages by advocating, influencing, innovating, mobilising efforts, and opening doors. This mission is realised through being a trusted source of information, advice, and support, as well as a committed partner in the development of new practices and approaches.

Amaze values: Achievement of the mission and vision depends on collaboration and community involvement. Amaze operates with a strengths-based approach, maintains independence, and supports the work of all partners. The organisation is held accountable to the following standards.

Community-centric: The Board and staff are representative of and dedicated to the community. Lived experience is valued and prioritised, ensuring the voices of Autistic people and families inform all efforts.
Collaboration and Partnership: A strong commitment to working with partners and stakeholders to achieve shared objectives.
Constructive and Solutions Focused: Embracing a change-maker mindset with a constructive and solution-oriented attitude.
Determination and Independence: Maintaining independence while offering a unique contribution to the field.
Evidence Informed and Outcomes Driven: Decisions and work are guided by the best available research, community insights, and practical evidence.
Strengths Based: Adopting a strengths-based rather than deficit-based perspective, highlighting the contributions Autistic people make and the societal benefits of their participation and inclusion.

Executive Summary

Amaze welcomes this opportunity to provide feedback on New Framework Planning and the NDIS Supports Rules. These reforms will have significant implications for Autistic NDIS participants. They will influence how support needs are identified, how funding decisions are made, how plans are reviewed and changed, and the types of disability-related supports participants can access.

We support the reform goal of improving consistency, transparency and equity in NDIS decision-making. However, these reforms will only succeed if they can accurately identify and respond to the support needs of all participants, including the support needs of Autistic people that may not be visible, that may fluctuate over time, or that may be influenced by co-occurring conditions or intersectional disadvantage.

The success of the new framework will also depend on whether participants can meaningfully engage in assessment and planning processes. This includes access to appropriate adjustments and supports, genuine choice regarding assessment conditions, clear explanations of how evidence is considered, and transparency on how Support Needs Assessments inform funding decisions. Participants must be able to understand how decisions are made, how plans can be reviewed/varied, and what rights and safeguards are available to them.

We also consider it critical that the NDIS Supports Rules provide greater clarity regarding supports commonly used by Autistic people and remain responsive to individual circumstances and changing support needs. Participants should not lose access to supports without suitable alternatives being available, and ongoing review of the support lists should occur in partnership with people with disability. Accessible, co-designed information and communication will be critical to supporting successful roll out of the reforms.

Key recommendations

Ensure Support Needs Assessments are accessible, inclusive and capable of accurately identifying support needs.
Require appropriately trained and accredited assessors with autism-specific expertise.
Provide participants with draft assessment reports and opportunities to identify inaccuracies before decisions are finalised.
Clearly explain how assessment findings inform funding amounts and other decisions in participant plans.
Use timely plan variations as the primary response to participant requested changes where a new assessment is not required.
Strengthen safeguards and procedural fairness for NDIA initiated plan changes.
Provide greater certainty regarding sensory, executive functioning and other supports commonly accessed by Autistic people.
Regularly review the supports rules with people with disability and safeguard participants during transition.
Deliver accessible, co-designed information and communications to support implementation of the reforms.

We welcome any further opportunity to discuss our submission and share our expertise, learnings and insights from community. Please contact me on (03) 96571600 or david.tonge@amaze.org.au.

Yours sincerely,

David Tonge
Chief Executive Officer

Key messages and recommendations.

1. Support Needs Assessment Rules

1.1 Ensure Support Needs Assessments are accessible and inclusive. Participants must have access to reasonable adjustments and supports throughout the assessment process, and genuine choice regarding assessment conditions, including whether assessments are conducted online or in person. Online assessments should not become the default, including in regional and remote areas.
1.2 Ensure Support Needs Assessments are capable of accurately capturing autistic support needs. Assessment processes must be designed to identify support needs that may not be immediately visible, may fluctuate over time, or may be influenced by co-occurring conditions or intersectional disadvantage.
1.3 Require appropriately trained and accredited assessors. Assessors should have autism-specific training, clear accreditation requirements and ongoing quality assurance arrangements to ensure assessments are consistent, evidence informed and responsive to the needs of different participant cohorts.
1.4 Strengthen transparency and procedural fairness. Participants should receive draft assessment reports before finalisation, have opportunities to identify inaccuracies or gaps, and be provided with clear explanations of how assessment findings were reached, including how participant, family and professional evidence was considered.

2. Budget Method Rules and Participant Plans

2.1 Clearly explain how assessment findings inform funding decisions. Participants should receive accessible information explaining how support needs translate into funding amounts, funding periods, restrictions, support categories and budget adjustments, including what evidence has been relied upon and how decisions have been reached.
2.2 Improve transparency within the participant plan template. The template should clearly explain how funding decisions have been made, including the rationale for funding restrictions, funding periods, plan management arrangements and any adjustments applied. It should also clearly identify which decisions are reviewable and explain participants’ rights to seek review or change.
2.3 Strengthen the participant plan template as an accessible and person-centred document. The template should give greater prominence to participants’ goals, strengths, preferences and aspirations, and include (or easily link to) clearer explanations of key concepts and decisions, and accessible information, examples and guidance to help participants understand and use their plan.

3. Plan Variations and Reassessments.

3.1 Prioritise plan variations over reassessments wherever possible. Participants should not be required to undergo a new Support Needs Assessment where changes can be addressed through a simpler and timelier variation process.
3.2 Support timely responses to changing circumstances. Plan variations should be available where support needs fluctuate, informal supports change, or service delivery is affected by thin markets or provider shortages.
3.3 Strengthen safeguards around NDIA-initiated changes. Participants should receive written reasons, access to relevant evidence and meaningful opportunities to respond before funding or supports are reduced.

4. NDIS Supports Rules

4.1 Provide greater clarity regarding supports commonly used by Autistic people. Clear guidance is needed regarding the status of sensory supports and executive functioning supports under the NDIS Supports Rules, including which support categories they fall within, when they may be funded, and what evidence participants may need to provide.
4.2 Retain flexibility to fund supports that address significant safety risks. Fencing and gates should remain fundable as a measure of last resort where there are demonstrated safety risks and less restrictive alternatives have been explored.
4.3 Provide greater practical guidance on how the Supports Rules will operate. Participants and providers will require examples, case studies and clear explanations to understand how supports are assessed, funded and categorised under the new framework.
4.4 Embed ongoing review of the support lists. The NDIS Supports Rules and support lists should be regularly reviewed and updated in partnership with people with disability to ensure they remain responsive to emerging evidence, participant experience and changing support needs.
4.5 Protect participants during transition. No participant should lose access to existing disability-related supports before alternative supports or arrangements are available, accessible and capable of meeting their needs. Where supports are excluded on the basis that they are the responsibility of another service system, the responsible service system should be clearly identified.

5. Implementation and Communication

5.1 Develop accessible, co-designed information and communications. Participants, families and carers should receive information developed with people with disability and available in a range of accessible formats.
5.2 Provide practical guidance on how the new framework will operate. Resources should include accessible case studies, examples, process maps and explanations of participant rights, safeguards and review pathways.
5.3 Partner with trusted disability organisations to support implementation. Community organisations can play a critical role in improving participant understanding, confidence and engagement with the reforms.

Introduction

We welcome this opportunity to provide feedback on New Framework Planning and the NDIS Supports Rules. The reforms present an opportunity to improve how support needs are identified, funded and supported through the NDIS. For Autistic people, however, the effectiveness of these reforms will depend on whether the new framework can accurately recognise support needs, support meaningful participant engagement, and deliver decisions that are transparent, evidence-informed and responsive to individual circumstances.

This submission focuses on practical opportunities to strengthen the proposed reforms, with particular emphasis on Support Needs Assessments, budget-setting and participant plans, plan variation and reassessment processes, and the NDIS Supports Rules. We have also highlighted areas where greater clarity, transparency and flexibility will be important to ensure the framework works effectively for Autistic people with diverse, intersectional and often fluctuating support needs. Our recommendations are intended to support a framework that is fair, accessible, person-centred and capable of responding to individual circumstances. We also support the recommendations of the Australian Autism Alliance and Disability Representative Organisations.

1. Support Needs Assessment rules

1.1 What parts of the Support Needs Assessment process need more explanation?

The parts of the Support Needs Assessment (SNA) process that need more explanation include:

How assessors will identify and address support needs that may not be readily captured through conversation-based assessments, including due to masking, fluctuating support needs, executive functioning difficulties, communication differences, sensory regulation needs, co-occurring conditions, literal interpretation, alexithymia, and other barriers to self-reporting support needs.
The qualifications, autism-specific training, accreditation requirements and ongoing quality assurance processes for assessors, including how consistency and assessment quality will be monitored across different assessors and participant cohorts.
What is meant in Attachment 4 by “NFP eligible participants are proposed to be funded a default community supports amount, rather than an amount determined through delegate discretion”? Does this mean all participants will receive the same amount, or will there be different levels? While we understand support determinations will apply equally, it was our understanding that these would be applied to case-by-case assessments, via the SNA, of community supports needs. Clearly support needs will vary significantly across participants.
How participants can request (and will be informed of their rights to request) reasonable adjustments, support people, advocates, interpreters, sensory accommodations, breaks, or multiple assessment sessions. Will participants have choice and control over assessors and assessment conditions, including whether an assessment is conducted in person or online? Will written reasons be required for any refusal to provide adjustments or refuse requests, and will review rights attach?
How evidence from treating health and allied health professionals will be used and weighted across all four parts of the SNA.
Timeframes, including how long participants will be given to prepare for their SNA and how they may be supported to do so through accessible, easy read resources and independent advocacy support.
The minimum information that will be required, or criteria that will be used to assess whether medical or allied health reports require a targeted assessment to be undertaken.
Whether the three components to support the targeted assessment process will be publicly available, i.e. the minimum requirements table, questionnaire and manual.
How the information gathered from the core needs assessment, PECQ and targeted assessments will be translated into the types of NDIS supports the participant needs and the SNA report. How participants can review, correct and challenge assessment findings and related decisions before an SNA report is finalised, to support procedural fairness, reduce the need for replacement assessments and promote cost-effectiveness in decision making.

1.2 What questions and feedback do you have about the draft support needs assessment report template?

The Support Needs Assessment report template should:

Better reflect participants’ strengths, preferences, interests and aspirations. The current template places much greater emphasis on functional limitations than on the person’s goals and desired outcomes.
Clearly explain how conclusions were reached, including what evidence was considered, how information from participants, families, carers and professionals was weighed, and how assessment findings will influence budgets.
Include a dedicated section documenting participant-requested adjustments, assessment conditions, communication preferences and factors that may have affected assessment outcomes (such as masking, anxiety, sensory overload, fatigue, executive functioning difficulties or communication differences). These factors are particularly important for Autistic participants and may significantly influence how support needs are presented during an assessment.
Clearly identify areas where the assessment tool may not have fully captured a participant’s support needs and summarise any additional evidence or assessor observations used to address those gaps. This is particularly important for support needs associated with executive functioning, sensory regulation, social communication, fluctuating support needs and co-occurring conditions.
To improve transparency in the cover letter:
- Under the sub-heading ‘Has your situation changed?’, clarify that changes in circumstances can include key education and employment transitions, such as starting or finishing school, changing schools, seeking work, accessing tertiary education, moving between supported and mainstream employment, or experiencing changes in the supports needed to obtain or maintain employment. It should also include changes in informal, community and mainstream supports.
- Provide an overview of the metrics Frequency of support and Level of support, including the measures used and their implications for identifying support needs and assessing budgets under the rules.
Given the significant role assessment reports play in determining budgets and supports, participants must have a meaningful opportunity to review findings in an accessible format and correct any inaccuracies before reports are finalised. Information provided only through a brief verbal summary at the end of an interview may be inaccessible for many people (including those experiencing communication, executive functioning, auditory processing, fatigue, or other barriers). Allowing participants to identify and meaningfully address errors at the draft stage is essential to procedural fairness and more cost-effective than requiring reassessment after finalisation.

1.3 In what circumstances do you think a replacement assessment should be arranged? Are there additional circumstances that should be considered?

A replacement assessment report should be arranged if:

The assessment failed to accurately capture the participant’s support needs, goals or circumstances.
Reasonable adjustments, communication supports, accessibility measures or support people were not provided.
Masking, anxiety, sensory overload or communication differences may have affected the assessment outcome.
Important evidence from the participant, family, carers or professionals was not considered.
New evidence emerges or changes occur in health, education, employment, living arrangements or support needs.

2. Budget method rules

2.1 Further information and details about the budget method calculations will be provided later in 2026 after more testing is done. What information would help participants understand how a budget is calculated?

The following information would help participants understand how a budget is calculated:

Accessible information for all participants about the new NDIS budget method rules, once operational, including transparent information about the 18 categories of supports and the process for determining funding (including evidence requirements, quotes etc) across each category.
Clear explanations of how assessment findings translate into funding amounts and funding periods.
Plain language examples showing how different support needs profiles affect budgets.
Transparent and accessible information about what factors can adjust a budget, including complexity, co-occurring conditions, location (i.e. rural and remote) and safeguarding needs.
Transparency regarding any algorithms or decision-making tools used in budget setting.
Information about review rights and how participants can seek budget changes if needs were not accurately captured.

2.2 What questions and feedback do you have about the draft participant plan template?

Our feedback regarding the draft participant plan template includes:

The draft Plan provides limited transparency about how support needs assessment findings were translated into funding amounts, making it difficult for participants to understand or challenge outcomes.
Participant goals, strengths, preferences and aspirations receive relatively little prominence compared with funding arrangements and administrative information, which risks reducing the person-centred focus of the plan.
The template does not adequately explain key concepts such as funding restrictions, funding periods, adjustments and support categories, or the practical implications these have for how participants can use their budgets. If not included in the template for simplicity, links to/attachments with accessible information regarding these concepts must be included.
The template does not identify how funding periods and plan management decisions were made, impacting transparency, choice and control and capacity to seek adjustments or review.
Information about flexible supports with restrictions (In-home and community supports) provides limited information about why this funding has been restricted. It simply states that funding has been restricted “..because you have high in-home care needs. There would be a safety risk if you don’t receive these supports.” Further information is needed to help the participant understand what these identified needs are and how this funding may be spent.
The Plan needs to be more transparent and educational about changes in circumstances that may impact the plan. As discussed above, key education and employment transitions should be expanded upon. It should also include changes in informal, community and mainstream supports.

The Plan does not explain which decisions in the Plan are reviewable decisions. Further information is needed to ensure Participants are fully aware of the decisions that may be subject to review and their related review rights. The Plan also fails to explain rights to internal review.
The template should be available in accessible formats and include clearer plain-language explanations, examples and visual supports to help participants understand their plan and exercise choice and control.

3. Plan variation and reassessment rules

3.1 What feedback and questions do you have about plan variations and reassessments?

Plan variations, where requested by participants, should be simple, accessible and significantly quicker than full reassessments. Participants should not need to undergo a new support needs assessment where a simpler variation process would resolve the issue.
We support the proposed grounds for plan variations. Participants should also be able to seek plan variations when:
- Support needs fluctuate, informal supports change or service delivery is disrupted by thin markets or provider shortages; and
- Both the participant and NDIA agree that a plan variation would provide a timelier and more cost-effective response than a full plan reassessment; and
- Any funding adjustment could be appropriately determined using the NDIS Budget Method Rule.
Plan reassessments should be reserved for situations where support needs have changed significantly, and a new support needs assessment is required to determine the participant’s support needs and calculate a revised budget under the NDIS Budget Method Rules.
To safeguard participants, the Rules should provide greater clarity regarding NDIA-initiated plan variations and reassessments. Where the NDIA proposes to reduce funding or supports, participants should receive written notice, access to the evidence relied upon, and a reasonable opportunity to respond. This is consistent with broader procedural fairness protections that should apply whenever the NDIA initiates a change that may adversely affect a participant.

4. NDIS supports rules.

4.1 What feedback do you have about changes to NDIS supports for old and new framework planning?

We maintain the view that a principles-based approach should underpin the NDIS Supports Rules. While supporting consistency, the rules should preserve flexibility, individualised decision-making and choice and control for Autistic people with diverse, intersectional and often fluctuating support needs. Our feedback on the proposed changes to NDIS supports for Old and New Framework Planning includes:

Greater clarity is required regarding sensory supports, and executive functioning supports commonly used by Autistic people. Clear guidance is needed on whether/in what circumstances these supports may be funded as NDIS Supports. Could they be funded under Assistive Technology — Other, In-home and Community Supports, or as stated supports? What evidence would be required? Participants, providers and NDIA staff need greater certainty regarding the status of these supports under the new framework to ensure consistency and fairness.
We are disappointed that electronic noise-cancelling headphones will be expressly excluded. While some Autistic people may be able to meet their sensory needs through environmental modifications, other supports or increased autism accessibility, many continue to rely on noise-cancelling headphones as an effective disability-related support. For these individuals, noise-cancelling headphones can provide a significant disability-related functional benefit by reducing sensory overload, supporting self-regulation, improving participation, reducing stress and anxiety, and enabling access to education, employment and community life, reducing social isolation.¹ While some studies have been inconsistent or have shown little to no significant effect², this is not surprising in an area that has been under-researched and people with lived experience have traditionally been excluded from research. Inconsistences across the studies can also clearly be linked to a range of research limitations, including a lack of consistent outcome measures, differences in use and conditions of use, and small sample sizes.
We are also concerned about the exclusion of fencing and gates. While these supports should not be routinely funded and should only be considered after less restrictive alternatives have been explored, they should remain fundable as a measure of last resort where there are significant safety risks. For a small cohort of Autistic participants who continue to abscond despite accessing appropriate therapies, behaviour supports and other interventions, fencing or gating can provide a critical safety safeguard and, in some circumstances, may be life-saving.
We support moves towards fewer and simpler support categories. However, participants will require more examples, case studies and practical guidance to understand how the rules apply in practice. Examples

¹ Kulawiak, P. R. (2021). Academic benefits of wearing noise-cancelling headphones during class for typically developing students and students with special needs: A scoping review. Cogent Education, 8(1). https://www.tandfonline.com/doi/pdf/10.1080/2331186X.2021.1957530; Zheng, L et al. (2022). The use of everyday and assistive technology in the lives of older autistic adults. Autism, 26(6), 1550-1562; Poulsen, R et al (2025). Auditory environments influence the link between Autistic traits and quality of life. Scientific Reports, 15(1). https://www.nature.com/articles/s41598-025-94585-y.pdf; Pfeiffer, B et al (2019). Effectiveness of Noise-Attenuating Headphones on Physiological Responses for Children With Autism Spectrum Disorders. Frontiers in Integrative Neuroscience, 13. https://www.frontiersin.org/articles/10.3389/fnint.2019.00065/pdf; Scheerer, N. E et al (2024) Autistic and Non-Autistic Experiences of Decreased Sound Tolerance and Their Association with Mental Health and Quality of Life. Autism in Adulthood. https://www.liebertpub.com/doi/abs/10.1089/aut.2023.0117; Pfeiffer, B et al (2019). Impact of Noise Attenuating Headphones on Participation in the Home, Community, and School for Children with Autism Spectrum Disorder. Physical & Occupational Therapy in Pediatrics, 39(1), 60-76; Roche, M. A et al (2024). Parental perspectives on the use of fidget toys and sensory-seeking profiles in autistic and neurotypical children. Current Psychology, 43(17), 15872-15882.

² Ibid Kulawiak, P (2021).

should reflect the diversity of the disability community, including Autistic people with different support needs and people experiencing intersectional disadvantage.

Embed ongoing co-design and review of the support lists. The support lists should be regularly reviewed and updated in partnership with people with disability, including Autistic people with diverse support needs and people experiencing intersectional disadvantage, to ensure they remain responsive to emerging evidence, community experience and changing support needs over time.
No participant should lose access to existing disability-related supports before alternative supports or arrangements are available, accessible and capable of meeting their needs.
On the List of supports that are not NDIS supports, where supports are listed on the basis that they are the responsibility of another service system, the service system responsible should be identified.

4.2 What impacts do you think will be experienced as a result of removing replacement supports? What items or services will no longer be available?

Removing replacement supports should reduce administrative burden and may make it easier for participants to access standard items that meet their disability-related support needs. However, there is a risk of confusion during transition if participants, providers and NDIA staff have different understandings of what can be funded under the new rules.
Clear, accessible guidance will be needed regarding which standard or commercially available items can be funded as stated supports and what evidence, if any, participants will need to provide. It remains unclear whether standard commercially available household items (that were previously funded as replacement supports) may continue to be funded as flexible or stated supports.
Participants should be able to access timely and cost-effective plan variations where changes in circumstances or fluctuations in support needs mean these types of supports become necessary, rather than requiring participants to undergo a lengthy reassessment process.

5. General questions.

5.1 What information was most useful?

Increased transparency and detail about what makes up the support needs assessment, and links to domains and assessment tools.
Increased transparency about the budget method, including categories of NDIS supports, flexible and stated supports, processes for determining budgets across categories and potential adjustments.
The opportunity to review a draft Support Needs Assessment and draft NDIS Plan.
Examples illustrating how plan variations and reassessments may operate.

5.2 What questions do you still have?

How the support needs assessment tool will continue to be tested and validated with Autistic people, including those from priority cohorts.
How the new framework will ensure equitable outcomes for Autistic people, including those high and complex support needs, co-occurring conditions and/or experiencing intersectional disadvantage.
How participants transitioning from the current framework will be protected from unintended reductions in support.

5.3 What would help people with disability better understand the NDIS NFP rules?

Easy Read resources, visual guides and real-world examples and case studies.
Information developed through co-design with people with disability, including Autistic people with a diversity of experiences and perspectives.
Clear explanations of participant rights, safeguards and review pathways.
Webinars, workshops and interactive information sessions.
Delivery of information through trusted disability and community organisations to improve reach, accessibility and participant confidence in the new framework.

5.4 What communication formats would make the information more accessible?

Easy Read documents and short videos.
Visual flowcharts and process maps.
Plain language webinars and community information sessions.
Information available in multiple languages and formats, compatible with assistive technology.

5.5 What should we focus on in future communication products?

Case studies and practical examples of how the new system will affect participants.
Rights, review pathways and safeguards.
Transparency regarding how budgets are calculated and reviewed.

How support needs assessments work in practice, participants’ rights to provide evidence, guidance on how evidence will be used, and what adjustments are available.
Clear, accessible guidance regarding which supports are funded by the NDIS and which are the responsibility of other systems.

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