Australian Autism Alliance

Submission to the consultation on New Framework Planning and NDIS Supports

Assess support needs as they are lived. Explain and adjust funding to meet those needs. Act early when risks emerge.

14 October 2026

Contents

• 1. Introduction

• 2. Overall position

• 3. The three framing points that shape this submission

• 4. Responses to the consultation questions

• 5. Conclusion

• Attachment A: What Autistic Australians have told us and what the evidence shows about assessment, budgets and supports

• Attachment B: Implementation and accountability tests for new framework planning

• Attachment C: Detailed comments on the draft NDIA templates

• Reference list

1. Introduction

The Australian Autism Alliance (‘the Alliance’) welcomes the opportunity to respond to the Department of Health, Disability and Ageing (‘the department’) consultation on both New Framework Planning and NDIS supports. The consultation covers the remaining four of the eight NDIS rules needed for New Framework Planning, being the rules for support needs assessment, the budget method, plan variations and reassessments and NDIS supports, together with proposed changes to the NDIS Supports Transitional Rules.^1,2 This submission responds to every consultation question in both papers and comments on the NDIA’s draft support needs assessment report and draft participant plan.^3,4 The Alliance may provide an Addendum to this submission by Monday 19 October 2026 to capture more specific feedback regarding NDIS Supports. The Alliance also looks forward to contributing to the further consultations later this year regarding the exposure drafts of all eight rules and the budget method calculations after more testing is done.¹

The Alliance is a funded national peak body and Disability Representative Organisation (DRO), providing a strong unifying voice for autism and authoritative policy expertise on autism. We work with Australian governments at all levels to strengthen policy and service systems affecting Autistic Australians. Our membership is a national network of organisations with diverse roles in autism, including organisations led by Autistic people, advocacy organisations, peak bodies, service providers and researchers.

Autistic people are the largest primary disability cohort in the NDIS. As at 31 March 2026, 338,099 active participants, approximately 44 per cent of all active participants, had autism recorded as their primary disability.⁵ Participants aged 18 and over will begin moving to new framework planning from April 2027, and the transition is expected to be complete for all participants by December 2030.¹ How support needs are assessed, how budgets are calculated and how supports are defined will therefore shape the daily lives of more Autistic people than of any other group in the Scheme.

This submission builds directly on the Alliance’s submission of 6 March 2026 to the first stage of this consultation, which covered the Notice of Impairment, Notice to have a New Framework Plan, New Framework Spending and Stated Supports rules,⁶ and on the Alliance’s recent submissions to the department’s consultations on NDIS access changes and on support coordination and connection reform. It also draws on the positions the Alliance put to the NDIA’s September 2026 consultation on plan reassessments, on the Alliance’s national evidence base, including the national consultation of more than 3,800 Autistic people, families and carers undertaken by Australian Catholic University for the Senate Select Committee on Autism,⁷ and on the research summarised at Attachment A. It reflects input from Alliance members, including lived experience and evidence based practice across areas such as assessment, therapy, positive behaviour support, community services, supported independent living and service navigation.

Attachment A summarises the evidence that informs the submission. Attachment B sets out implementation and accountability tests drawn from the Alliance’s Systems That Work™ approach. Attachment C provides detailed comments on the two draft NDIA templates.

2. Overall position

The Alliance supports the objectives of New Framework Planning: planning that is more consistent, more transparent and more focused on each participant’s support needs, with longer plans and more flexible funding that give participants greater choice and control. In March 2026 the Alliance welcomed the move away from highly variable line by line decision making toward whole of person budgeting,⁶ and that support stands. Several features of the current papers respond to issues raised in the first stage of consultation. Current plans will remain in place until a new framework plan is approved; participants keep their review and appeal rights; participants will be able to request interpreter services, communication supports and accessibility requirements when they book an assessment, and the NDIA will arrange and pay for interpreters; and the most commonly requested smart devices will become stated supports.^1,2 The Alliance acknowledges these changes.

The Alliance’s focus is now on implementation. New framework planning is legislated, the NDIA is testing the assessment and budget method with participants, and exposure drafts of all eight rules are expected later in 2026.¹ The Alliance is not asking the department to hold the reform back until every element has been proven, or to apply every safeguard to every participant. We propose a workable risk management architecture that protects people at the points where failure can be identified. As transition to New Framework Planning proceeds, defined triggers bring a proportionate safeguard into play for a particular person where assessment, budget or transition risk emerges. Each safeguard has a named trigger, people who can activate it, a record, and a measure that tells government whether it is working. The six triggered safeguards are set out in the table that follows the summary of recommendations.

For Autistic participants, three issues will decide whether new framework planning works. First, support need must be assessed as it is lived, with the supports that currently hold a person’s life together made visible rather than mistaken for independence. Second, a budget must be explainable to the person it funds, including any assumption about the support family members will provide. Third, the rules must respond quickly when circumstances change, because an Autistic person’s support needs can change sharply with burnout, a transition or the loss of a key supporter while the underlying disability stays the same. Section 3 develops these three framing points.

These priorities reflect the Alliance’s Make the Invisible Visible approach: assessment must identify support that is easily overlooked, budget decisions must show how assessed needs and individual circumstances have been considered, and safeguards must enable timely correction when standard assumptions fail. The operational test is whether the process identifies, verifies and responds to individual support needs without requiring Autistic people and families to repeatedly prove established needs or navigate avoidable administrative barriers.

On NDIS supports, the Alliance supports simpler, purpose-based categories, and clearer rules that improve flexibility, choice and access. However, consolidating categories must not inadvertently narrow the functions of existing supports or create new barriers to meeting assessed disability-related needs. The Alliance calls for a clear reconciliation of existing and proposed support functions, clarification of flexible and stated funding arrangements, and a timely pathway for participants to access newly identified supports. We also ask the department to reconsider two proposed exclusions that bear directly on Autistic people, where these meet disability-related sensory regulation or safety needs. Electronic noise-cancelling headphones and fencing and gates are, for some Autistic people and families, sensory regulation and safety supports linked directly to disability. We also ask the department to keep a narrow, evidence-based exception pathway when the replacement supports process is removed. The test is

whether the revised rules preserve access to appropriate supports in practice, not simply whether the categories are easier to administer.

Summary of recommendations

The Alliance’s recommendations are summarised here and developed through the paper. The six triggered safeguards that give practical effect to them follow the summary.

Recommendation 1: Assess support need as it is lived. Require the support needs assessment rules and assessor instructions to record support need across settings and over time, and with and without the informal, environmental and funded supports currently in place. Assessors should establish whether everyday activities can be done safely, reliably, repeatedly and sustainably, including the preparation, prompting and recovery they require, and should actively explore communication, sensory processing, executive functioning, masking, fatigue and Autistic burnout rather than relying on the participant to raise them. The assessment should draw on existing evidence from treating professionals, families, educators and others who know the person well, and the report should record what was considered. The ability to undertake an activity on one occasion, or in a familiar or supported environment, must not alone be treated as evidence that it can be undertaken independently, safely, reliably, repeatedly and sustainably. Where reliable existing evidence establishes ongoing support needs, further assessment should be confined to material questions that remain unresolved. Where the assessment method has not demonstrated validity for the participant’s relevant circumstances, or there is an elevated risk of underestimating need, additional evidence or appropriately qualified professional judgement should inform the decision.

Recommendation 2: Treat adjustments as part of a valid assessment. Write the booking stage adjustments now described in the consultation paper into the rules, including augmentative and alternative communication (AAC), written or pre-submitted information, multiple shorter sessions, a choice of setting and mode, a support person of the participant’s choosing and the option of private time with the assessor. Participants should receive accessible information about the assessment domains and indicative questions in advance, with sufficient opportunity to prepare and provide relevant evidence. Assessors should proactively identify and offer appropriate adjustments, rather than relying solely on participants to request them. Record which adjustments were offered, requested and provided, whether they were effective, and whether any failure to provide them materially affected assessment validity. Back assessor training with autism capability standards, supervision, calibration and independent quality assurance.

Recommendation 3: Make the support needs assessment report a document participants can check and correct. Revise the draft report to explain the frequency and level scales in plain language; add structured fields for communication and adjustments, sensory and regulation needs, variability of need, masking, protective supports and the evidence considered; explain any evidence that ‘did not meet our requirements’ by saying what is missing, how to provide it and who will pay for it; and provide a defined, supported correction window, with any disagreement recorded, before the budget is calculated (Attachment C). The report should show how significant support needs were identified, which evidence informed each material finding, how conflicting evidence was resolved and how those findings will inform the budget. Assessors and delegates should proactively identify material omissions or discrepancies, rather than relying solely on the participant to raise them. Before assessment findings are finalised for budget determination,

should be offered an accessible opportunity to verify that their circumstances and support needs have been accurately understood, including how information they provided has been interpreted and what findings may materially affect their budget. This should be a supported verification step, distinct from a subsequent review or appeal.

Recommendation 4: Set out replacement assessment triggers in the rules. Arrange a replacement assessment where there is a material factual error or omitted evidence; a requested adjustment was not provided; the assessment took place during Autistic burnout, crisis, acute illness or a major transition; masking, distress or the assessment environment materially affected the conversation; the report conflicts with existing evidence without explanation; the presence of another person prevented the participant from speaking freely; a procedural, capability or conflict of interest concern arises; or circumstances change significantly before the plan is approved. A request should never place current supports at risk, and a participant should be able to have a trusted person or independent advocate help them make it. Where a factual correction, supplementary evidence or additional assessment session can reliably resolve the concern, that proportionate response should be used. A full replacement assessment should be arranged where the original assessment cannot reliably support the decision. Where there is a material, unresolved concern that the assessment has underestimated the participant’s support needs, the assessment must not be relied upon as the sole basis for determining the budget until the concern has been appropriately examined. Supplementary evidence, specialist professional judgement or a replacement assessment should be used where necessary, without requiring unnecessary duplication of established evidence.

Recommendation 5: Publish the budget method with worked examples, and explain every budget. Before the exposure drafts are finalised, publish the calculation steps, assumptions, default amounts, adjustments and offsets, with worked examples that include Autistic participants with different support profiles including variable, high-intensity and continuous support needs. Every participant plan should include a plain language explanation linking each material assessed support need to the relevant funding category, calculation method and resulting amount, including the assumptions, default amounts, adjustments, offsets and restrictions applied. Participants must be able to understand how their assessed needs produced their budget, identify incorrect assumptions or unexplained discrepancies, and seek correction before those errors adversely affect their supports.

Recommendation 6: Make informal support assumptions visible and correctable. Where the informal supports offset is applied to in-home and community supports, show the assumed contribution, the evidence for it and how its durability was assessed, including the supporter’s willingness, age, health, employment and other caring responsibilities. Do not assume that family members of an adult participant will provide disability support they have not agreed to provide. For children, distinguish ordinary age-appropriate parental responsibility from additional disability-related support, considering its nature, intensity, frequency, duration and complexity, including overnight supervision or assistance. Existing parental effort should not automatically be treated as a sustainable contribution or funding offset. Treat a change in informal support as a trigger for a plan variation.

Recommendation 7: Allow documented individualised adjustment where default and set funding levels do not meet assessed need.

Where a default community supports amount, set funding level or relative needs level does not adequately meet the support needs identified in the assessment, including where an

assessed shared-support ratio cannot safely or practically be delivered, require the delegate to consider an individualised adjustment and record the evidence, decision and reasons. This must include circumstances where standardised assumptions fail to account for fluctuating support intensity, continuous or near-continuous support availability, active assistance, overnight supervision, immediate response capacity, unsafe or unavailable shared-support arrangements, or additional disability-related support needs not adequately reflected in the calculation.

A proposed budget that removes or materially reduces an existing support that prevents a foreseeable safety, health, housing or functional risk must trigger documented individual scrutiny, irrespective of the percentage reduction in the overall budget. The delegate must establish how the assessed need and protective function will continue to be met, including verifying that any proposed alternative support is available, accessible and suitable for the participant.

Where an alternative cannot be verified, it must not be relied upon to justify a reduction in funded support without further individual consideration. The delegate must consider whether an adjustment is necessary and provide documented reasons for the decision, including where an adjustment is not made.

Monitor individualised budget adjustment requests, decisions and outcomes by disability cohort, including reductions in protective supports and subsequent reviews or adverse outcomes.

Recommendation 8: Set funding periods and restrictions to fit the person. Set funding periods with the participant, with longer periods as the default for people whose needs fluctuate, and give reasons and review information whenever flexible funding is restricted or a requirement is applied. Funding arrangements should accommodate foreseeable periods of increased support need, including transitions and episodes of Autistic burnout, and allow participants to use available flexible funding across funding periods where permitted, without an unnecessary reassessment. Any limits on that flexibility should be clearly explained.

Recommendation 9: Make plan variations fast, supported and safe. Publish clear criteria, evidence requirements and decision timeframes for variations and reassessments. Establish a priority pathway with interim funding where a change in circumstances creates a risk to health, safety, housing, essential supports or the sustainability of informal support. Allow foreseeable transitions, including leaving school, changes in living arrangements and other significant life transitions, to be planned ahead through a variation without requiring an unnecessary full assessment. Ensure participants are not disadvantaged for seeking the wrong type of plan change.

Establish a pathway to alert an NDIA officer with authority to consider and determine urgent interim arrangements, with published triage and escalation timeframes, clear evidence requirements, and a requirement to communicate and record decisions and reasons. Essential supports should be maintained while serious risks are considered, with proportionate interim arrangements where required.

Participants must be able to seek a variation or reassessment with assistance from a trusted supporter or independent advocate. Where a participant’s circumstances have changed significantly but disability-related barriers prevent them from initiating the process, an independent advocate should be able to alert the NDIA so it can engage proactively with the participant, without the advocate having to become their legal nominee, subject to appropriate consent, privacy and safeguarding requirements.

Recommendation 10: Replace blanket exclusions with assessed need for sensory and safety supports. Do not add electronic noise-cancelling headphones or fencing and gates to Schedule 2 as unqualified exclusions. Exclude them where they are not related to disability, and allow them where a targeted assessment or treating professional identifies a disability-related sensory regulation or safety need, with behaviour support input where fencing or gates could restrict a person’s freedom of movement. Decisions should distinguish disability-related environmental safety measures from restrictive practices, with appropriate safeguards where a measure may restrict a person’s rights or freedom of movement. The functional purpose, individual circumstances and evidence of need should determine whether the support is appropriate. At a minimum, confirm that passive hearing protection remains fundable.

Recommendation 11: Retain an effective exception pathway when replacement supports are removed. Support simplifying the replacement supports process and including commonly requested smart devices as stated supports. However, the existing process should not be removed until an effective, lawful and accessible alternative is established for individual disability-related needs that cannot be adequately addressed through the revised support categories.

Retain a narrow, evidence-based pathway for low-cost items that deliver a disability-related functional outcome at equal or lower cost than the support they replace. The Department should identify the lawful mechanism for individual exceptions or equivalent flexibility, including eligibility criteria, evidence requirements, the authorised decision-maker, decision timeframes, written reasons and review rights.

Honour existing approvals and provide clear transitional arrangements for pending and in-progress requests. Participants who already use a tablet, communication app or other approved device should not be required to duplicate existing evidence or undergo an unnecessary new targeted assessment to maintain access.

Provide a timely, proportionate pathway for participants to obtain newly identified stated supports after plan approval, including where the need emerges without an urgent change in circumstances. The Department should specify the applicable planning or variation mechanism for old and new framework participants, without automatically requiring a full reassessment.

Recommendation 12: Close the gaps between the papers and the templates. Reconcile support category names and numbering across the two consultation papers, the fact sheets and the draft templates; confirm where early childhood intervention supports sit; and confirm in the rules or guidance that supports in the current rules that are not expressly carried into the new descriptions remain available, including support for people with complex communication needs or behaviours when accessing health services and hospitals, travel training, and capacity building in managing money and relationships. Require a support-function reconciliation between the current and proposed categories, identifying any intended changes in eligibility or scope and expressly preserving assistance to establish and sustain tenancies, practical assistance with life transitions and associated disability-related support functions. Provide practical guidance for decisions involving overlapping NDIS, health, education, community or other service responsibilities, including how decision-makers should establish whether an alternative support is genuinely available and suitable. The Department should clarify how assessment and selection, fitting or configuration, repair,

maintenance, replacement and safe disposal of assistive technology and equipment are covered by the revised categories, including where an item is essential to communication, sensory regulation or safety. Participants should not be required to resolve disagreements between systems before their individual support needs can be properly considered. The Department should also confirm that the broader category descriptions do not unintentionally exclude disability-related supports for self-regulation and co-regulation, motor planning, executive functioning, complex communication, social interaction, personal care, supported decision-making, short-term accommodation and the maintenance of existing functional capacity. The rules and accompanying guidance should distinguish supports that maintain or sustain functioning from supports intended to develop new skills, and should not treat these purposes as mutually exclusive.

Recommendation 13: Communicate in ways that work for Autistic people. Co-design and test autism-specific participant examples with the Alliance, and provide literal, predictable, step by step information that explains what will happen, who will make contact and how, what to prepare and what to do if something goes wrong, in Easy Read, visual, Auslan, translated and spoken formats, including face to face options. Accessible communication must also extend to participation in the process itself, including submitting evidence, reviewing assessment findings, identifying omissions or inaccuracies, requesting corrections and seeking a variation or review. Participants should be able to use their preferred communication method and obtain appropriate assistance at each stage.

Recommendation 14: Monitor outcomes by cohort and act on what the data show. Publish disaggregated data on assessment, budget and plan change outcomes, including for Autistic participants and relevant support profiles. Establish predefined thresholds that trigger investigation and review of an assessment component, budget rule, support rule or operational practice where evidence indicates that a cohort is systematically disadvantaged.

Monitoring should include assessment adjustments and validity concerns, use of existing evidence, material report corrections, replacement assessment requests and outcomes, individualised budget adjustments, material budget reductions, urgent variations, interim funding decisions, disruption or withdrawal of protective supports, unmet assessed needs, adverse outcomes and resolution times.

Establish baseline and follow-up measures that distinguish administrative outputs from outcomes for participants, including safety, choice and control, participation, wellbeing and the sustainability of support arrangements.

Where recurring problems or adverse outcomes are identified, require documented corrective action, including the responsible decision-maker, timeframe and evidence that the action has addressed the problem. Publish findings and corrective actions in aggregate, with appropriate privacy protections.

Complete an independent early implementation review within the first year of rollout, including analysis of outcomes for Autistic participants and whether the assessment, budgeting, support and correction mechanisms are operating effectively.

Triggered safeguards: how government can manage risk proportionately

The table below sets out how government can manage implementation risk without imposing every safeguard on every participant. Each safeguard applies only when its trigger occurs. The table shows who can trigger each safeguard, how it is recorded and how government will know whether it is working. The recommendation numbers in the first column show where each safeguard is developed in this submission.

Trigger	Safeguard that applies	Who can trigger it, and how it is recorded	How government knows it is working
1. Assessment validity concern (Recs 1, 2, 4) A requested adjustment was not provided; the assessment took place during burnout, crisis or acute illness; masking or distress materially affected it; or the report conflicts with existing evidence without explanation. The assessment method has not demonstrated validity for the participant’s relevant circumstances, or there is an identified risk of underestimating support needs. Reliable existing evidence may also establish support needs that should not require repeated assessment.	Supplementary evidence is sought, or a replacement assessment arranged, before the budget is calculated. The current plan continues meanwhile. Where validity is uncertain or false-negative risk is elevated, obtain additional evidence or appropriately qualified professional judgement before relying on the affected findings for budget determination. Reuse reliable existing evidence and limit further assessment to material questions that remain unresolved. Correct or supplement the assessment where sufficient; arrange a replacement assessment only where the original cannot reliably support the decision.	Participant, nominee, supporter or advocate; assessor; delegate. Recorded in adjustment report and in the replacement assessment decision. The assessor or delegate must identify and escalate validity concerns, including concerns raised by the participant, supporter or advocate. Record the concern, evidence considered, action taken and reasons for relying on the final findings.	Proportion of requested adjustments provided; replacement assessment requests and outcomes by cohort; decisions later changed because evidence was missed. Monitor validity concerns identified and resolved before budget determination, use of existing evidence, supplementary assessments, replacement assessments and instances of material underestimation subsequently corrected.
2. Disputed report content (Rec 3) The participant identifies a factual error, an omission or an interpretation they disagree with. A material inconsistency, omission or unresolved discrepancy is identified by the assessor or delegate, even where the participant has not formally disputed the report	A defined, supported correction window before the budget is calculated, a written response from the delegate, and any remaining disagreement recorded with the report. Require the assessor or delegate to identify and resolve material discrepancies before the affected findings are relied upon for budget determination. Where necessary, obtain secondary consideration by an appropriately qualified person. Provide the participant with an accessible opportunity to verify and correct the account.	Participant, nominee, supporter or advocate. Recorded in a corrections log and a disagreement section of the report. The assessor or delegate must also initiate the safeguard when a material discrepancy is identified. Record the discrepancy, evidence considered, resolution and any secondary consideration.	Correction rates and time to resolution; proportion of corrections accepted; reviews linked to report errors. Monitor material discrepancies identified proactively, corrections completed before budget determination and subsequent reviews arising from unresolved report inaccuracies.

System level monitoring sits behind all six safeguards. Recommendation 14 calls for publication of outcomes by disability cohort and predefined thresholds that trigger review where participants are systematically disadvantaged.

Aggregated assessment, budget adjustment, report correction, review, complaint and independent advocacy data should be monitored by disability cohort and relevant support profile. Where predefined thresholds identify recurring underestimation of need, material assessment errors, unexplained budget disparities or repeated failures of an adjustment or correction pathway, the NDIA should investigate the affected assessment component, budget assumption or operational practice and implement a documented corrective response.

Corrective action should be proportionate to the identified problem and may include revised assessor guidance, additional evidence requirements, specialist review, recalibration of a budget assumption or modification of the affected decision process. The responsible authority, corrective action, timeframe and outcome should be recorded and reported publicly in aggregate.

Attachment B sets out the Alliance’s implementation and accountability tests in more detail.

3. The three framing points that shape this submission

a. Support need must be assessed as it is lived, with the support around the person made visible

The support needs assessment will be a guided conversation between a participant and a trained, accredited NDIA assessor. Its core needs assessment covers 12 domains and records the frequency and level of support needed, and is based on a modified version of the Instrument for the Classification and Assessment of Support Needs (I-CAN) version 6. It is supplemented by a personal and environmental circumstances questionnaire and, where needed, by targeted assessments.¹ The I-CAN’s developer describes it as a holistic support needs assessment tool based on the World Health Organization International Classification of Functioning, Disability and Health (ICF) and validated for people with disability aged 16 and over.⁸

For Autistic people, what a person can do on the day of an assessment is often a poor guide to the support they need. Autistic functioning is shaped by sensory load, communication demands, predictability, executive functioning and the presence of trusted people, and it can change from one setting to the next and from one week to the next. Camouflaging or masking can make difficulties hard to see in a structured conversation with a stranger, and Autistic burnout can reduce capacity for long periods without any change in the underlying disability (Attachment A, section 3).^9,10,11,12 A guided conversation on one day may capture a person’s best day, or a day in burnout, and in either case it may not accurately represent their ongoing support needs.

The most important design principle for Autistic participants is therefore to make the support around the person visible. Prompting, supervision, visual schedules, predictable routines, adjustments at school or work, co-regulation by a family member and funded supports can all create the appearance of capacity. The draft support needs assessment report already records some of this, for example where a participant can complete a task ‘with verbal prompting’ or follows a visual aid in the bathroom.³ The Alliance supports that approach and asks that it be required consistently. For each area of life the assessment should establish what the person can do, what enables them to do it, what it costs them to sustain it, and what happens if that support is reduced or removed. Effective support is evidence that the support is working. It should never become evidence that the need has gone. This requires assessment to distinguish between observable achievement, supported functioning and independent capacity, rather than treating them as interchangeable. Consistency should come from standardising the assessment process and evidence requirements, not assuming that people who demonstrate similar abilities have the same support needs.

In March 2026 the Alliance asked for evidence that the assessment can reliably capture the diversity of Autistic support needs before it determines funding.⁶ That evidence remains important, and the NDIA’s live testing is the opportunity to produce it. Consistent with its focus on implementation, the Alliance asks that testing results for Autistic participants be published as they become available, and that the adjustments and triggered safeguards in this submission apply from the first assessments. The reform can then proceed while the evidence builds, with a clear route to correct individual assessments that miss what matters.

Recommendation 1: Assess support need as it is lived. Require the support needs assessment rules and assessor instructions to record support need across settings and over time, and with and without the informal, environmental and funded supports currently in place. Assessors should establish whether everyday activities can be done safely, reliably, repeatedly and sustainably, including the preparation, prompting and recovery they require, and should actively explore communication, sensory processing, executive functioning,

masking, fatigue and Autistic burnout rather than relying on the participant to raise them. The assessment should draw on existing evidence from treating professionals, families, educators and others who know the person well, and the report should record what was considered. The ability to undertake an activity on one occasion, or in a familiar or supported environment, must not alone be treated as evidence that it can be undertaken independently, safely, reliably, repeatedly and sustainably. Where reliable existing evidence establishes ongoing support needs, further assessment should be confined to material questions that remain unresolved. Where the assessment method has not demonstrated validity for the participant’s relevant circumstances, or there is an elevated risk of underestimating need, additional evidence or appropriately qualified professional judgement should inform the decision.

Recommendation 2: Treat adjustments as part of a valid assessment. Write the booking stage adjustments now described in the consultation paper into the rules, including augmentative and alternative communication (AAC), written or pre-submitted information, multiple shorter sessions, a choice of setting and mode, a support person of the participant’s choosing and the option of private time with the assessor. Participants should receive accessible information about the assessment domains and indicative questions in advance, with sufficient opportunity to prepare and provide relevant evidence. Assessors should proactively identify and offer appropriate adjustments, rather than relying solely on participants to request them. Record which adjustments were offered, requested and provided, whether they were effective, and whether any failure to provide them materially affected assessment validity. Back assessor training with autism capability standards, supervision, calibration and independent quality assurance.

b. A budget must be explainable to the person it funds

The budget method will convert the support needs assessment report into a reasonable and necessary budget. The department has described five mechanisms: a direct estimate of hours of support, a relative estimate that maps assessment outcomes to needs levels, quotes or benchmark prices, funding amounts set by policy decision, and single funding levels.13 The detailed calculations will not be released until later in 2026, after further testing.1

Several of the settings that will most affect Autistic participants sit inside this method. In-home and community supports will be subject to an informal supports offset ‘based on frequency and durability of informal support’. Eligible participants are proposed to receive a default community supports amount rather than an amount set through delegate discretion. Therapy and support coordination funding will be derived from relative needs levels, and behaviour support will be funded at set levels.1,13 None of these settings can yet be tested by participants or their representatives. The draft participant plan shows total, flexible and stated funding clearly, but it does not show how any of those amounts were reached.4

A consistent method will only be trusted if participants can see how it was applied to them. Every participant should be able to trace each assessed need to the funding in their plan, see any offset or adjustment that changed the amount, and correct an assumption that is wrong. This matters most for the informal supports offset. Many Autistic adults rely heavily on family members for prompting, coordination, transport and emotional regulation, often because other supports have not been available, and the Senate Select Committee on Autism reported that 73.4 per cent of parents and carers of Autistic people felt socially isolated (Attachment A, section 4).7 Support that families provide today, often at real cost to themselves, should not silently reduce a participant’s budget on the assumption that it will continue.

Recommendation 5: Publish the budget method with worked examples, and explain every budget. Before the exposure drafts are finalised, publish the calculation steps, assumptions, default amounts, adjustments and offsets, with worked examples that include Autistic participants with different support profiles including variable, high-intensity and continuous support needs. Every participant plan should include a plain language explanation linking each material assessed support need to the relevant funding category, calculation method and resulting amount, including the assumptions, default amounts, adjustments, offsets and restrictions applied. Participants must be able to understand how their assessed needs produced their budget, identify incorrect assumptions or unexplained discrepancies, and seek correction before those errors adversely affect their supports.

Recommendation 6: Make informal support assumptions visible and correctable. Where the informal supports offset is applied to in-home and community supports, show the assumed contribution, the evidence for it and how its durability was assessed, including the supporter’s willingness, age, health, employment and other caring responsibilities. Do not assume that family members of an adult participant will provide disability support they have not agreed to provide. For children, distinguish ordinary age-appropriate parental responsibility from additional disability-related support, considering its nature, intensity, frequency, duration and complexity, including overnight supervision or assistance. Existing parental effort should not automatically be treated as a sustainable contribution or funding offset. Treat a change in informal support as a trigger for a plan variation.

Recommendation 7: Allow documented individualised adjustment where default and set funding levels do not meet assessed need. Where a default community supports amount, set funding level or relative needs level does not adequately meet the support needs identified in the assessment, including where an assessed shared-support ratio cannot safely or practically be delivered, require the delegate to consider an individualised adjustment and record the evidence, decision and reasons. This must include circumstances where standardised assumptions fail to account for fluctuating support intensity, continuous or near-continuous support availability, active assistance, overnight supervision, immediate response capacity, unsafe or unavailable shared-support arrangements, or additional disability-related support needs not adequately reflected in the calculation.

A proposed budget that removes or materially reduces an existing support that prevents a foreseeable safety, health, housing or functional risk must trigger documented individual scrutiny, irrespective of the percentage reduction in the overall budget. The delegate must establish how the assessed need and protective function will continue to be met, including verifying that any proposed alternative support is available, accessible and suitable for the participant.

Where an alternative cannot be verified, it must not be relied upon to justify a reduction in funded support without further individual consideration. The delegate must consider whether an adjustment is necessary and provide documented reasons for the decision, including where an adjustment is not made.

Monitor individualised budget adjustment requests, decisions and outcomes by disability cohort, including reductions in protective supports and subsequent reviews or adverse outcomes.

c. Proportionate, triggered safeguards allow the reform to proceed safely

The Alliance’s Systems That Work™ approach asks a practical question of every reform: did implementation leave Autistic people safer and better supported, and does government know

whether it did? Applied to new framework planning, that question does not require every surrounding system to be ready before anyone moves to a new plan. It requires a response at the points where failure can be identified. Those points are an assessment that missed something important, a report that is wrong, a budget that does not add up, a carer who can no longer provide support, a crisis, and an item that is no longer available.

This approach draws on the Alliance’s Systems That Work for Everyone framework, which applies six interconnected tests: Readiness, Accountability, Safeguards, Savings, Evidence and Outcomes. At this stage of reform, those tests are applied to practical assessment, budgeting, support and correction processes rather than as a request to delay implementation. Through its Systems That Work Lab, the Alliance intends to invite Autistic people, families, representative organisations, researchers and other stakeholders to test how the framework and its operational safeguards work in practice, including assessment validity, budget adjustments, support exclusions and correction pathways. The Alliance welcomes opportunities to contribute this collaborative testing approach as the exposure drafts are developed.

The department has already built some continuity into the design. Current plans remain in place until a new framework plan is approved, participants keep review and appeal rights, and most plan changes are to be made through variations rather than full reassessments.1,14 The six triggered safeguards build on those features. They apply only when a trigger occurs, so most participants will move through new framework planning without needing any of them. Where a trigger does occur, the safeguard is defined in advance, the person or organisation that can activate it is named, the response is recorded, and the data tell government whether the safeguard is working and whether a rule or tool needs to change.

This approach also reflects a principle the Alliance put to the NDIA’s consultation on plan reassessments in September 2026: participant control must not be confused with administrative independence. Some of the people most likely to need a replacement assessment, a plan variation or a reassessment are those least able to start one, because the change in their circumstances is also affecting their capacity to organise, communicate and complete paperwork. Each triggered safeguard can therefore be activated with the help of a trusted person or independent advocate, and the most urgent can be activated by others who can see that risk is emerging.

Recommendation 9: Make plan variations fast, supported and safe. Publish clear criteria, evidence requirements and decision timeframes for variations and reassessments. Establish a priority pathway with interim funding where a change in circumstances creates a risk to health, safety, housing, essential supports or the sustainability of informal support. Allow foreseeable transitions, including leaving school, changes in living arrangements and other significant life transitions, to be planned ahead through a variation without requiring an unnecessary full assessment. Ensure participants are not disadvantaged for seeking the wrong type of plan change.

Establish a pathway to alert an NDIA officer with authority to consider and determine urgent interim arrangements, with published triage and escalation timeframes, clear evidence requirements, and a requirement to communicate and record decisions and reasons. Essential supports should be maintained while serious risks are considered, with proportionate interim arrangements where required.

Participants must be able to seek a variation or reassessment with assistance from a trusted supporter or independent advocate. Where a participant’s circumstances have changed significantly but disability-related barriers prevent them from initiating the process, an

independent advocate should be able to alert the NDIA so it can engage proactively with the participant, without the advocate having to become their legal nominee, subject to appropriate consent, privacy and safeguarding requirements.

Recommendation 14: Monitor outcomes by cohort and act on what the data show. Publish disaggregated data on assessment, budget and plan change outcomes, including for Autistic participants and relevant support profiles. Establish predefined thresholds that trigger investigation and review of an assessment component, budget rule, support rule or operational practice where evidence indicates that a cohort is systematically disadvantaged.

Monitoring should include assessment adjustments and validity concerns, use of existing evidence, material report corrections, replacement assessment requests and outcomes, individualised budget adjustments, material budget reductions, urgent variations, interim funding decisions, disruption or withdrawal of protective supports, unmet assessed needs, adverse outcomes and resolution times.

Establish baseline and follow-up measures that distinguish administrative outputs from outcomes for participants, including safety, choice and control, participation, wellbeing and the sustainability of support arrangements.

Where recurring problems or adverse outcomes are identified, require documented corrective action, including the responsible decision-maker, timeframe and evidence that the action has addressed the problem. Publish findings and corrective actions in aggregate, with appropriate privacy protections.

Complete an independent early implementation review within the first year of rollout, including analysis of outcomes for Autistic participants and whether the assessment, budgeting, support and correction mechanisms are operating effectively.

4. Responses to the consultation questions

The Alliance’s responses follow the structure of the two consultation papers. Part A responds to the questions on the new framework planning rules, Part B to the questions on NDIS supports in both papers, and Part C to the general questions. The table below maps each question to the relevant sections, recommendations and attachments of this submission.

No.	Consultation question	Traceability in this submission
1	What parts of the support needs assessment process need more explanation?	Sections 3(a) and 4(a); Recommendations 1 and 2; Attachment A sections 3 and 5
2	What questions and feedback do you have about the draft support needs assessment report template?	Section 4(b); Recommendation 3; Attachment C, part 1
3	In what circumstances do you think a replacement assessment should be arranged? Are there additional circumstances that should be considered?	Section 4(c); Recommendation 4; triggered safeguards 1 and 2
4	What information would help participants understand how a budget is calculated?	Sections 3(b) and 4(d); Recommendations 5, 6 and 7; triggered safeguards 3 and 4
5	What questions and feedback do you have about the draft participant plan template?	Section 4(e); Recommendations 5 and 8; Attachment C, part 2
6	What feedback and questions do you have about plan variations and reassessments?	Sections 3(c) and 4(f); Recommendation 9; triggered safeguard 5
7	What feedback do you have about changes to NDIS supports for old and new framework planning?	Section 4(g); Recommendation 12
8	Are the proposed support categories clear, and are there areas or support types where further explanation, examples or guidance would be helpful? (NDIS supports paper)	Section 4(g); Recommendation 12
9	What impacts do you think will be experienced as a result of removing replacement supports? What items or services will no longer be available?	Section 4(h); Recommendation 11; triggered safeguard 6; Attachment A section 7
10	Are there any practical issues, or unintended impacts, that need to be considered? (NDIS supports paper)	Section 4(i); Recommendations 10 and 12; triggered safeguard 6; Attachment A section 6
11	General questions: what information was most useful, what questions do you still have, what would help people with disability better understand the rules, what communication formats would make the information more accessible, and what should future communication products focus on?	Section 4(j); Recommendations 13 and 14

Part A: New framework planning rules

a. What parts of the support needs assessment process need more explanation?

The consultation paper and fact sheet give a clear outline of the four parts of the assessment and the participant experience.1,15 The October update adding information about requesting adjustments at the booking stage is welcome. Autistic participants and families will need more explanation of the following matters before they can prepare for an assessment with confidence:

• Adjustments. What can be requested at booking, how a request is confirmed, and what happens if it is not provided on the day. Participants need to know whether they can use AAC, provide written or pre-prepared information, take breaks, split the assessment across several shorter sessions, choose a familiar setting or a remote option, bring a support person of their choice, and speak privately with the assessor.
• Length and format. How long the assessment takes and how it adapts to a participant who becomes overloaded or shuts down part way through. The draft report shows an assessment held over two dates, which the Alliance welcomes as a model.3
• Existing evidence. How reports from treating professionals, written accounts from family members, education and employment records and existing NDIS evidence will be considered and weighted, and when an assessor must seek discipline-specific evidence rather than rely on the conversation alone.
• Informal supports. That the answers a participant or family gives about informal support in the personal and environmental circumstances questionnaire may reduce funding through the informal supports offset. Participants should know this before they answer, so that they can describe the support honestly, including support that is unsustainable or that they do not want to continue.
• Masking, fluctuation and burnout. How the assessor will identify needs that are masked, hidden or normalised, how needs that vary over weeks or months will be captured, and what a participant should do if the assessment falls during a period of burnout or crisis.
• The scores. What the frequency scale (never to daily) and the level of support scale (independent to extensive) mean, and how the scores connect to the budget.
• Cost of evidence. Who pays for any evidence required for a targeted assessment. The draft report tells participants in some cases that ‘a comprehensive external report is needed’.3 Evidence requirements should not become a capacity to pay test for supports.
• Assessor capability. What qualifications, accreditation and autism capability assessors will have. The NDIA has said the first cohort of assessors will be allied health professionals who complete an accreditation process,16 and participants should be told what to do if they believe their assessor did not understand their disability.
• Notices. How the Notice of Impairment, which participants who have not yet received one will begin receiving from 1 February 2027,15 relates to the support needs assessment, and how errors in either can be corrected.

Underlying these questions is the design principle in section 3(a). The assessment should make the invisible visible, so that an Autistic person is not required to perform their disability in an assessment encounter. Questions should actively explore sensory processing, communication under stress, executive functioning, recovery time and the support that sustains everyday activities, because many Autistic people will not raise these needs unprompted. The NDIA’s own co-design working group has recorded the question ‘What will be the result of neurotypical people assessing Autistic people?’,16 and the answer depends on assessor capability that is backed by standards, supervision, calibration and quality assurance, not on training alone.

Recommendation 1: Assess support need as it is lived. Require the support needs assessment rules and assessor instructions to record support need across settings and over time, and with and without the informal, environmental and funded supports currently in place. Assessors should establish whether everyday activities can be done safely, reliably, repeatedly and sustainably, including the preparation, prompting and recovery they require, and should actively explore communication, sensory processing, executive functioning,

masking, fatigue and Autistic burnout rather than relying on the participant to raise them. The assessment should draw on existing evidence from treating professionals, families, educators and others who know the person well, and the report should record what was considered.

Recommendation 2: Treat adjustments as part of a valid assessment. Write the booking stage adjustments now described in the consultation paper into the rules, including augmentative and alternative communication (AAC), written or pre-submitted information, multiple shorter sessions, a choice of setting and mode, a support person of the participant’s choosing and the option of private time with the assessor. Record which adjustments were requested and which were provided. Back assessor training with autism capability standards, supervision, calibration and independent quality assurance.

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

The draft report has several strengths. It is written to the participant in plain language, it is shared before the plan is prepared, it records prompting and other support that is in place, it records informal supports and the participant’s circle of support, it accepts a written account from a family member as evidence, and its ‘assessor’s comments’ field is intended to explain where requirements were not met.3 The Alliance supports each of these features.

For the report to be a document that Autistic participants can check, understand and correct, the Alliance recommends the following changes. Attachment C sets them out in detail.

• Explain the frequency and level scales in plain language, and show how the scores will be used in the budget.
• Replace the single statement about communication (‘You do not need support with communication’) with a communication profile that records preferred communication methods, AAC use, processing time, the adjustments requested and the adjustments provided.
• Add structured fields for sensory and regulation needs, variability of need over time, masking or presenting differently in unfamiliar settings, protective supports and what happens if they are reduced, and a list of the evidence considered and the weight given to it.
• Where information ‘did not meet our requirements’, say what was missing, how the participant can provide it, by when, and who will pay for it.
• Expand ‘What you need to do’ to give a defined period to raise errors before the budget is calculated, explain that help is available from a trusted person or advocate, and include a section where the participant’s disagreement is recorded if it is not resolved.
• Align the names of the ‘assessed supports’ with the 18 support categories. The draft lists ‘Daily Supports (flexible)’ and ‘Travel and transport arrangements (flexible)’, while Attachment 3 to the consultation paper lists in-home and community supports and private vehicle transport, which is a stated support.1

These changes reflect the standardised report fields the Alliance recommended in March 2026, adjusted to the template the NDIA has now released.6

Recommendation 3: Make the support needs assessment report a document participants can check and correct. Revise the draft report to explain the frequency and level scales in plain language; add structured fields for communication and adjustments, sensory and regulation needs, variability of need, masking, protective supports and the evidence considered; explain any evidence that ‘did not meet our requirements’ by saying

what is missing, how to provide it and who will pay for it; and provide a defined, supported correction window, with any disagreement recorded, before the budget is calculated (Attachment C). The report should show how significant support needs were identified, which evidence informed each material finding, how conflicting evidence was resolved and how those findings will inform the budget. Assessors and delegates should proactively identify material omissions or discrepancies, rather than relying solely on the participant to raise them. Before assessment findings are finalised for budget determination, participants should be offered an accessible opportunity to verify that their circumstances and support needs have been accurately understood, including how information they provided has been interpreted and what findings may materially affect their budget. This should be a supported verification step, distinct from a subsequent review or appeal.

c. In what circumstances should a replacement assessment be arranged?

The consultation paper says that if a participant is concerned about the assessment process or the report, the NDIA delegate will work with them to decide whether a replacement assessment is needed, and that the rules will set out the situations in which a delegate should arrange one.1 The Alliance supports placing these circumstances in the rules. In March 2026 the Alliance proposed six triggers.6 Drawing on member experience since then, the Alliance recommends that a replacement assessment be arranged in the following circumstances:

1. the report contains a material factual error, or relevant evidence was not considered;
2. an adjustment the participant requested, or clearly needed, was not provided, so that the participant could not communicate their needs;
3. the assessment took place during Autistic burnout, a mental health crisis, acute illness or a major transition, and does not reflect the participant’s usual support needs;
4. masking, distress, fatigue or an unfamiliar environment materially affected the conversation;
5. the report conflicts materially with existing evidence from treating professionals, family or other sources without explaining why;
6. the presence of another person, including a family member or provider, prevented the participant from speaking freely, including about safety;
7. a procedural error, an assessor capability concern or a conflict of interest is identified; or
8. the participant’s circumstances change significantly between the assessment and plan approval, for example through the loss of an informal supporter, a change in housing or hospital admission.

Three process safeguards should apply. First, a request should never put current supports at risk, and the current plan should continue while the request is considered, consistent with the paper’s commitment that current plans remain in place until a new plan is approved.1 Second, the participant should be able to make the request with the help of a trusted person or independent advocate, and a request should not be refused because it was framed imperfectly. Third, the delegate should decide within a published timeframe and give reasons, and a replacement assessment arising from a capability or conflict concern should be conducted by a different assessor. Many of these situations can be resolved without a full replacement assessment, through supplementary evidence or an additional session, and the rules should allow that proportionate response.

Recommendation 4: Set out replacement assessment triggers in the rules. Arrange a replacement assessment where there is a material factual error or omitted evidence; a requested adjustment was not provided; the assessment took place during Autistic burnout, crisis, acute illness or a major transition; masking, distress or the assessment environment materially affected the conversation; the report conflicts with existing evidence without explanation; the presence of another person prevented the participant from speaking freely; a procedural, capability or conflict of interest concern arises; or circumstances change significantly before the plan is approved. A request should never place current supports at risk, and a participant should be able to have a trusted person or independent advocate help them make it. Where a factual correction, supplementary evidence or additional assessment session can reliably resolve the concern, that proportionate response should be used. A full replacement assessment should be arranged where the original assessment cannot reliably support the decision. Where there is a material, unresolved concern that the assessment has underestimated the participant’s support needs, the assessment must not be relied upon as the sole basis for determining the budget until the concern has been appropriately examined. Supplementary evidence, specialist professional judgement or a replacement assessment should be used where necessary, without requiring unnecessary duplication of established evidence.

d. What information would help participants understand how a budget is calculated?

The department has said that detailed calculations will be provided later in 2026.1 The Alliance notes that participants and their representatives are being asked to comment on a budget method whose calculations are not yet available, which limits what anyone can usefully say about whether it will meet Autistic participants’ needs. The Alliance would welcome the opportunity to test worked examples for Autistic participants with the department and the NDIA before the exposure drafts are finalised. To understand and trust a budget, participants will need:

• a plain language explanation of each of the five funding mechanisms, and which mechanism applies to each support category;13
• worked examples covering different ages, living arrangements, communication profiles, co-occurring conditions and levels of informal support, including Autistic participants who live alone, with family and in shared living;
• a statement in each plan showing how the assessed needs produced the funding in each category, and which adjustments, offsets, default amounts and restrictions were applied;
• the assumed informal support contribution, the evidence for it and how it can be corrected (Recommendation 6);
• how therapy funding levels are set, including whether they cover indirect work such as communication partner training, carer coaching, AAC programming and collaboration with schools and workplaces, which member organisations identify as essential to therapy outcomes for many Autistic participants;
• how the default community supports amount was set, and what happens where a participant’s assessed need is higher than the default;
• how behaviour support set levels adjust for complexity, including the work needed to reduce and eliminate restrictive practices;

• how a budget based on a shared support ratio will be adjusted where no compatible arrangement is available, since an assessed ratio of 1:2 or 1:3 is not deliverable unless a suitable grouping exists; and
• how budgets for plans of up to five years will keep pace with price changes, and what evidence a participant needs to correct an assumption or seek a variation.

The informal supports offset requires particular care. The durability of informal support should be assessed with the supporter, not inferred from the fact that support is being provided today. Relevant factors include the supporter’s willingness, age, health, employment and other caring responsibilities, the participant’s own wishes about who supports them, and what will happen if that support breaks down. For adult participants, the rules should not assume that parents or other family members will continue to provide disability support they have not agreed to provide.

The budget methodology must also distinguish between different forms of support need, including continuous or near-continuous support availability, active assistance, overnight supervision, immediate response capacity and shared-support arrangements. These are not interchangeable. A participant may require someone to be available to respond throughout the day or night, even where direct assistance is intermittent. Equally, a shared-support ratio may be inappropriate where the person requires individual supervision, timely intervention or support that cannot safely be shared. Budget calculations should reflect the actual nature, intensity, timing and availability of support required, rather than converting all needs into discrete hours of task-based assistance.

Recommendation 5: Publish the budget method with worked examples, and explain every budget. Before the exposure drafts are finalised, publish the calculation steps, assumptions, default amounts, adjustments and offsets, with worked examples that include Autistic participants with different support profiles, including variable, high-intensity and continuous support needs. Every participant plan should include a plain language explanation linking each material assessed support need to the relevant funding category, calculation method and resulting amount, including the assumptions, default amounts, adjustments, offsets and restrictions applied. Participants must be able to understand how their assessed needs produced their budget, identify incorrect assumptions or unexplained discrepancies, and seek correction before those errors adversely affect their supports.

Recommendation 6: Make informal support assumptions visible and correctable. Where the informal supports offset is applied to in-home and community supports, show the assumed contribution, the evidence for it and how its durability was assessed, including the supporter’s willingness, age, health, employment and other caring responsibilities. Do not assume that family members of an adult participant will provide disability support they have not agreed to provide. For children, distinguish ordinary age-appropriate parental responsibility from additional disability-related support, considering its nature, intensity, frequency, duration and complexity, including overnight supervision or assistance. Existing parental effort should not automatically be treated as a sustainable contribution or funding offset. Treat a change in informal support as a trigger for a plan variation.

Recommendation 7: Allow documented individualised adjustment where default and set funding levels do not meet assessed need. Where a default community supports amount, set funding level or relative needs level does not adequately meet the support needs identified in the assessment, including where an assessed shared-support ratio cannot safely or practically be delivered, require the delegate to consider an individualised adjustment and record the evidence, decision and reasons. This must include circumstances where standardised assumptions fail to account for fluctuating support intensity, continuous or near-

continuous support availability, active assistance, overnight supervision, immediate response capacity, unsafe or unavailable shared-support arrangements, or additional disability-related support needs not adequately reflected in the calculation.

A proposed budget that removes or materially reduces an existing support that prevents a foreseeable safety, health, housing or functional risk must trigger documented individual scrutiny, irrespective of the percentage reduction in the overall budget. The delegate must establish how the assessed need and protective function will continue to be met, including verifying that any proposed alternative support is available, accessible and suitable for the participant.

Where an alternative cannot be verified, it must not be relied upon to justify a reduction in funded support without further individual consideration. The delegate must consider whether an adjustment is necessary and provide documented reasons for the decision, including where an adjustment is not made.

Monitor individualised budget adjustment requests, decisions and outcomes by disability cohort, including reductions in protective supports and subsequent reviews or adverse outcomes.

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

The draft plan presents the total, flexible and stated funding clearly, distinguishes flexible funding with and without restrictions, records the participant’s goals in their own words, describes their strengths and informal supports, and sets out a funding period schedule with unspent funds rolling over.4 These are good features. The main gaps are the following:

• There is no section explaining how the budget was worked out. The plan should link goals, assessed needs, support categories and funding, and show any offset, adjustment or default amount applied (Recommendation 5).
• Restrictions and requirements are explained briefly (for example, ‘This funding has been restricted because you have high in-home care needs’) without telling the participant how to ask for a restriction to be reviewed. In March 2026 the Alliance recommended that restrictions be used cautiously, with reasons and review rights.6
• The example uses three month funding periods across a three year plan. Short funding periods can disadvantage participants whose needs fluctuate, including Autistic participants who experience burnout. The Alliance recommended in March 2026 that funding periods be set with participants, with longer periods as the default.6
• The review section describes applying to the Administrative Review Tribunal after an internal review outcome letter, but a participant receiving a new plan has not yet had an internal review. The template should first explain how to request an internal review of the plan decision.
• There is no section on what to do if safety or critical supports change. The plan should tell participants how to seek an urgent variation and who to contact, and identify supports that must continue during a provider change, variation or review.
• The template contains errors that should be corrected before release, including a funding period of ‘01 November 2026 to 31 January 2028’ (repeated in each schedule), a total of ‘$330,00.00’, and a section numbered 5 where the contents list shows four sections.

Recommendation 8: Set funding periods and restrictions to fit the person. Set funding periods with the participant, with longer periods as the default for people whose needs fluctuate, and give reasons and review information whenever flexible funding is restricted or a requirement is applied. Funding arrangements should accommodate foreseeable periods of increased support need, including transitions and episodes of Autistic burnout, and allow participants to use available flexible funding across funding periods where permitted, without an unnecessary reassessment. Any limits on that flexibility should be clearly explained

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

The Alliance supports the intention that most plan updates be made through plan variations, with full reassessments reserved for significant and ongoing changes.1,14 This was a recommendation in the Alliance’s March 2026 submission.6 For Autistic participants the following matters are important.

Functional change can occur without any change in the underlying autism. Burnout, increasing demands, a transition, the loss of informal support or the breakdown of existing supports can substantially change support needs. Guidance should explain this, and evidence requirements should focus on what has changed. Older evidence may remain relevant to the person’s disability and baseline, and participants should not assume that every change requires a new, expensive functional assessment.

Participants should not be disadvantaged for choosing the wrong pathway. The line between a variation for ‘small changes’ and a reassessment for ‘significant and ongoing’ changes will not always be clear to participants. A request made under the wrong pathway should be redirected, not refused. Guidance should also say whether an increase in in-home supports following a breakdown of informal support can be made by variation while a reassessment is arranged.

Urgent changes need an urgent pathway. The fact sheet lists crisis or emergency situations and risks to health or safety as reasons for a variation.14 The rules should set out priority triage, interim funding within a published timeframe, and continuity of essential supports while a decision is made. Triggers should include burnout, hospital admission or discharge, housing or placement breakdown, carer illness or death, safeguarding concerns and an increase in the use of restrictive practices.

Foreseeable transitions should be planned ahead. Leaving school, starting work, moving house and the ageing of a family carer are predictable. Funding for transition planning, visits and gradual introduction to new services should be available through a variation before the change, so that support does not start only when school support stops.

Changes in therapy intensity should be possible through a variation, for example when a participant begins using AAC, after a significant life transition or when a new functional need emerges, without requiring a full reassessment. Longer plans must be able to accommodate needs that change over time.

Supported requests and an advocate alert pathway. Consistent with the Alliance’s input to the NDIA’s plan reassessment consultation, the participant should be able to make a request with the help of a trusted person or independent advocate without being told that only they can make it. Where a participant’s circumstances have changed significantly but disability-related barriers prevent them from starting the process, an independent advocate should be able to alert the NDIA so that the NDIA can engage with the participant proactively. This is not a request made on the participant’s behalf. It is an early warning that allows the NDIA to act before a crisis.

Needing help with the process should not be treated as evidence that the participant needs a nominee, consistent with supported decision-making principles.17

Measure the gateway. Monitoring should look not only at the number of variations and reassessments approved, but at requests found invalid, requests abandoned, the time taken to establish a valid request, the assistance and adjustments required, and whether particular cohorts are disproportionately unable to get through.

Recommendation 9: Make plan variations fast, supported and safe. Publish clear criteria, evidence requirements and decision timeframes for variations and reassessments. Establish a priority pathway with interim funding where a change in circumstances creates a risk to health, safety, housing, essential supports or the sustainability of informal support. Allow foreseeable transitions, including leaving school, changes in living arrangements and other significant life transitions, to be planned ahead through a variation without requiring an unnecessary full assessment. Ensure participants are not disadvantaged for seeking the wrong type of plan change.

Establish a pathway to alert an NDIA officer with authority to consider and determine urgent interim arrangements, with published triage and escalation timeframes, clear evidence requirements, and a requirement to communicate and record decisions and reasons. Essential supports should be maintained while serious risks are considered, with proportionate interim arrangements where required.

Participants must be able to seek a variation or reassessment with assistance from a trusted supporter or independent advocate. Where a participant’s circumstances have changed significantly but disability-related barriers prevent them from initiating the process, an independent advocate should be able to alert the NDIA so it can engage proactively with the participant, without the advocate having to become their legal nominee, subject to appropriate consent, privacy and safeguarding requirements.

Part B: NDIS supports

g. Changes to NDIS supports for old and new framework planning, and the clarity of the proposed categories

The Alliance supports the move from 36 categories based on provider registration groups to 18 purpose based categories, the use of a single list across old and new framework planning, the clarification that supports can be bought from retailers, pharmacies and hardware stores, and the clarification of when animal-assisted therapy can be funded.2 The department has said the changes are not intended to remove broad types of supports.2 To give that commitment practical effect, the following matters need attention.

Inconsistent names and numbering. The mapping at Attachment 1 to the NDIS supports paper refers to new categories numbered up to 20, including ‘7. Early intervention supports for early childhood’, ‘16. Short term respite’, ‘19. Support coordination’ and ‘20. Therapy support’, while the list of 18 categories in both papers does not include an early intervention category and uses ‘Short term accommodation’.2,1 The budget fact sheet uses ‘Short term respite’,13 and the draft report uses names that do not appear in either list. The mapping also expresses the early childhood age ranges differently from the current rules (0 to 9 years and 0 to 6 years in the current text, 0 to 8 years and 0 to 5 years in the amending text). The department should confirm where early childhood intervention supports will sit and whether any change in eligibility is intended. This matters to Autistic children and their families, for whom timely early intervention is a priority.

Supports not expressly carried into the new descriptions. The Alliance has compared the current and amending columns of Attachment 1. Some supports that Autistic participants use are not expressly mentioned in the new descriptions. These include supports for people with complex communication needs or behaviours when accessing health or mental health services, including hospitals (current item 16(b)); travel training to use public transport safely and independently (item 6(f)); building capacity to manage finances and to improve relationship skills (item 15(c) and (g)); visual and tactile alerting systems (item 9(i)); and modified or adaptive clothing and products to manage menstruation (item 9). The Alliance asks the department to confirm that each remains an NDIS support where it meets the rules, and to say so in guidance.2

Also, category consolidation must preserve the full function of existing supports, not merely map category names. In particular, the proposed Support coordination description should expressly retain capacity-building, guidance, prompting and practical assistance to find, establish, maintain and sustain appropriate accommodation, including preventing avoidable tenancy breakdown. The descriptions should also preserve practical assistance to prepare for, navigate and sustain transitions involving education, employment, housing, hospital discharge, mental health and custodial settings, with clear responsibility where activities cross stated and flexible categories. The Department should confirm the treatment of disability-related end-of-life veterinary care and humane disposal for assistance animals, and retain the express coverage of design, planning, implementation, certification, maintenance and repair of home modifications. A support-function reconciliation should identify any intended changes in eligibility or scope.

Examples relevant to autism. The purpose based descriptions would be easier to apply with examples drawn from Autistic participants’ lives, including sensory regulation equipment, visual schedules and timers, AAC apps and devices, communication partner training, indirect therapy, supports for school and post-school transitions and positive behaviour support that builds social skills for participation, which the new behaviour support description now includes.2

Importantly, positive behaviour support should not be understood solely through behaviours of concern or the management of restrictive practices². For Autistic people, effective support may include identifying communication and sensory needs, adapting environments, developing self-regulation and co-regulation strategies, supporting communication partners and maintaining safe participation in home, education and community settings. The rules and guidance should clarify how these preventative and capacity-maintaining functions are funded, including where they overlap with therapy, everyday supports and behaviour support, without requiring a restrictive practice or crisis before support can be justified.

Flexible and stated supports. The supports paper says it is proposed that most supports would be flexible,2 but 10 of the 18 categories are stated.1 Several stated categories are used heavily by Autistic participants, including support coordination, behaviour support, assistive technology assets, short term accommodation and private vehicle transport. The Alliance’s March 2026 position remains that stated supports should be minimal, clearly justified and reviewable, and should not prevent participants from choosing their provider and delivery model unless safety or integrity require it.6 The draft plan’s requirement to use a registered provider for support coordination will need to be monitored in thin markets.4

The rules and participant plan should clearly distinguish flexibility to purchase different eligible supports within a category from flexibility to use funding across categories, and explain when funding is restricted or a support must be specifically stated. Participants should not be left to infer these limits from category names alone.

The new ‘assessed need’ condition. The supports fact sheet states that supports may be available ‘where there is an assessed need’, in addition to generally and where stated in the

plan.18 The department should explain how this condition will apply to the many participants who remain on old framework plans and have not had a support needs assessment.

Recommendation 12: Close the gaps between the papers and the templates. Reconcile support category names and numbering across the two consultation papers, the fact sheets and the draft templates; confirm where early childhood intervention supports sit; and confirm in the rules or guidance that supports in the current rules that are not expressly carried into the new descriptions remain available, including support for people with complex communication needs or behaviours when accessing health services and hospitals, travel training, and capacity building in managing money and relationships.

Require a support-function reconciliation between the current and proposed categories, identifying any intended changes in eligibility or scope and expressly preserving assistance to establish and sustain tenancies, practical assistance with life transitions and associated disability-related support functions. Provide practical guidance for decisions involving overlapping NDIS, health, education, community or other service responsibilities, including how decision-makers should establish whether an alternative support is genuinely available and suitable. The Department should clarify how assessment and selection, fitting or configuration, repair, maintenance, replacement and safe disposal of assistive technology and equipment are covered by the revised categories, including where an item is essential to communication, sensory regulation or safety. Participants should not be required to resolve disagreements between systems before their individual support needs can be properly considered. The Department should also confirm that the broader category descriptions do not unintentionally exclude disability-related supports for self-regulation and co-regulation, motor planning, executive functioning, complex communication, social interaction, personal care, supported decision-making, short-term accommodation and the maintenance of existing functional capacity. The rules and accompanying guidance should distinguish supports that maintain or sustain functioning from supports intended to develop new skills, and should not treat these purposes as mutually exclusive.

h. What impacts will result from removing replacement supports, and what will no longer be available?

As at 17 July 2026, 11,051 replacement support requests had been received. Of these, 5,545 had been approved, 1,995 refused, 1,439 were invalid and 2,072 were pending, with 1,951 in progress. The most requested items were tablets, accessibility and communication apps, smart watches and smart phones.2 The Alliance supports the proposal to include these items as stated supports where they meet the relevant requirements, and recognises that the replacement process has been confusing for participants.

The removal of the process will nonetheless have the following impacts, which the rules and guidance should address:

• Items on the current replacement list beyond devices, such as standard household items including washing machines and dishwashers,19 will no longer be available through this route, including where they reduced reliance on paid support.
• Low-cost or emerging items that deliver a disability-related functional benefit, such as digital prompting and scheduling tools, sensory regulation supports and smart home safety technology, may have no pathway at all unless they fit an existing category.
• Because smart devices will become stated supports, access will depend on a targeted assessment for participants on new framework plans, including the communication

module.1 A participant who already uses a tablet or app to communicate should not need a new report to keep it, and the evidence already held should be accepted.

• Participants on old framework plans will need to have these items found reasonable and necessary in their plan.2 The department should explain how and when this will happen, how existing approvals carry over, and how pending and in-progress requests will be finalised.

A narrow exception pathway would preserve the useful function of the replacement process without its complexity. It should apply where an item is safe, directly related to the participant’s disability support needs, likely to deliver a measurable functional outcome, and costs the same as or less than the support it replaces.

The proposed inclusion of smart devices as stated supports also raises a separate access issue. Participants may only discover a need for a communication device, accessibility app or other stated support after their plan has been approved. The rules should provide a timely, proportionate pathway to add a newly identified stated support without automatically requiring a full reassessment, using existing evidence where appropriate. This pathway should be available for emerging needs as well as urgent circumstances, with clear evidence requirements, decision timeframes, reasons and review rights. The Department should explain how equivalent access will operate for participants on old framework plans.

The Department should identify the specific planning or variation mechanism, authorised decision-maker and expected decision timeframe for adding a newly identified stated support, including where there is no urgent change in circumstances.

Recommendation 11: Retain an effective exception pathway when replacement supports are removed. Support simplifying the replacement supports process and including commonly requested smart devices as stated supports. However, the existing process should not be removed until an effective, lawful and accessible alternative is established for individual disability-related needs that cannot be adequately addressed through the revised support categories.

Retain a narrow, evidence-based pathway for low-cost items that deliver a disability-related functional outcome at equal or lower cost than the support they replace. The Department should identify the lawful mechanism for individual exceptions or equivalent flexibility, including eligibility criteria, evidence requirements, the authorised decision-maker, decision timeframes, written reasons and review rights.

Honour existing approvals and provide clear transitional arrangements for pending and in-progress requests. Participants who already use a tablet, communication app or other approved device should not be required to duplicate existing evidence or undergo an unnecessary new targeted assessment to maintain access.

Provide a timely, proportionate pathway for participants to obtain newly identified stated supports after plan approval, including where the need emerges without an urgent change in circumstances. The Department should specify the applicable planning or variation mechanism for old and new framework participants, without automatically requiring a full reassessment.

i. Are there practical issues or unintended impacts that need to be considered?

Electronic noise-cancelling headphones. Hyper- or hypo reactivity to sensory input is one of the diagnostic criteria for autism,20 and auditory sensitivity can make ordinary environments such as public transport, shops, classrooms and workplaces difficult or impossible to tolerate. Small

studies suggest that noise-attenuating headphones can reduce physiological stress responses and help Autistic children cope with auditory hyper-reactivity.21,22 The evidence base is small, and headphones will not suit every Autistic person. That is an argument for assessing need individually, not for a categorical exclusion. For some Autistic people, headphones are the support that makes it possible to travel independently, attend school or work, or take part in community activities without a support worker. The paper explains the exclusion as a response to confusion and disputes.2 Clearer guidance about when headphones are a disability-related support would address that confusion without removing the support from people who need it. At a minimum, the department should confirm that passive hearing protection, such as earmuffs, remains fundable under assistive technology.

Fencing and gates. In a United States study of more than 1,200 Autistic children, 49 per cent had attempted to elope at least once after the age of four. Of those who went missing, 65 per cent had a close call with traffic and 24 per cent a close call with drowning.23,24 For some families of Autistic children and adults, secure fencing is the disability-related safety support that allows a person to be outdoors at home without constant one to one supervision. The Alliance also recognises that fencing and locked gates can operate as an environmental restraint where they restrict a person’s freedom of movement, and should then be considered within the restrictive practices framework with behaviour support input. Both points support individual assessment over a blanket exclusion, which would leave families to manage serious safety risks without funding or guidance.

Other practical issues. The department should also consider the following:

• Transport. Many Autistic people cannot use public transport because of sensory overload, unpredictability or safety risk, rather than physical access. The assessment of transport need should take these factors into account, and travel training should remain available.
• Support coordination. The policy table notes potential changes to support coordination arising from commissioning reform.1 The Alliance’s submission on support coordination and connection reform sets out the safeguards needed so that participants do not lose coordination during that transition.
• Health and hospital access. Autistic people with complex communication needs or behaviours may need disability support to access health services and hospitals safely. The new disability-related health supports description should confirm this remains available.
• One list for two frameworks. Because the changes will apply to participants on old framework plans as well as new, the department should publish a transition guide showing how each current support maps to the new categories in practice.

Recommendation 10: Replace blanket exclusions with assessed need for sensory and safety supports. Do not add electronic noise-cancelling headphones or fencing and gates to Schedule 2 as unqualified exclusions. Exclude them where they are not related to disability, and allow them where a targeted assessment or treating professional identifies a disability-related sensory regulation or safety need, with behaviour support input where fencing or gates could restrict a person’s freedom of movement. Decisions should distinguish disability-related environmental safety measures from restrictive practices, with appropriate safeguards where a measure may restrict a person’s rights or freedom of movement. The functional purpose, individual circumstances and evidence of need should determine whether the support is appropriate. At a minimum, confirm that passive hearing protection remains fundable.

Part C: General questions

j. Useful information, remaining questions, understanding and communication formats

What was most useful. Attachment 4 to the new framework planning paper, which sets out the assessment pathway, funding type, funding process and adjustments for each category, was the most useful material, together with the draft report and draft plan, which let participants see what they will receive. The fact sheet examples and the October update on adjustments at booking were also helpful.1,15

Questions that remain. The main questions Autistic participants and families still have are: how the budget will be calculated in their case; how the informal supports offset will work; what the default community supports amount will be; how the NDIA’s testing results for Autistic participants will be reported; how much notice they will receive before moving to a new framework plan; how and when participants under 18 will transition; and how the rules will be reviewed and corrected after they commence.

What would help people understand. Worked examples are the single most helpful tool, including autism-specific examples covering different ages, living arrangements and support needs, tested with Autistic people before release. A side by side comparison of current and new arrangements, and a ‘what changes for me’ guide, would also help.

Accessible formats. For Autistic people, accessibility goes beyond Easy Read. Information should be literal, predictable and step by step, and should explain what will happen, who will make contact and how, what information is needed, what happens if something is missing, and what the possible outcomes are. Visual process maps and decision trees, short captioned videos, Auslan, translated material and screen reader and AAC friendly digital formats should all be available. Reducing uncertainty is itself an accessibility measure. Some people will need to talk the information through with a person, by phone or face to face, and families and supporters need their own guidance.

Future focus. Future products should focus on how to prepare for a support needs assessment, how to check and correct a report, how a budget was worked out, how to request a variation, especially urgently, and what to do if something goes wrong.

Recommendation 13: Communicate in ways that work for Autistic people. Co-design and test autism-specific participant examples with the Alliance, and provide literal, predictable, step by step information that explains what will happen, who will make contact and how, what to prepare and what to do if something goes wrong, in Easy Read, visual, Auslan, translated and spoken formats, including face to face options. Accessible communication must also extend to participation in the process itself, including submitting evidence, reviewing assessment findings, identifying omissions or inaccuracies, requesting corrections and seeking a variation or review. Participants should be able to use their preferred communication method and obtain appropriate assistance at each stage.

Recommendation 14: Monitor outcomes by cohort and act on what the data show. Publish disaggregated data on assessment, budget and plan change outcomes, including for Autistic participants and relevant support profiles. Establish predefined thresholds that trigger investigation and review of an assessment component, budget rule, support rule or operational practice where evidence indicates that a cohort is systematically disadvantaged.

Monitoring should include assessment adjustments and validity concerns, use of existing evidence, material report corrections, replacement assessment requests and outcomes,

individualised budget adjustments, material budget reductions, urgent variations, interim funding decisions, disruption or withdrawal of protective supports, unmet assessed needs, adverse outcomes and resolution times.

Establish baseline and follow-up measures that distinguish administrative outputs from outcomes for participants, including safety, choice and control, participation, wellbeing and the sustainability of support arrangements.

Where recurring problems or adverse outcomes are identified, require documented corrective action, including the responsible decision-maker, timeframe and evidence that the action has addressed the problem. Publish findings and corrective actions in aggregate, with appropriate privacy protections.

Complete an independent early implementation review within the first year of rollout, including analysis of outcomes for Autistic participants and whether the assessment, budgeting, support and correction mechanisms are operating effectively.

5. Conclusion

New Framework Planning offers an opportunity to make NDIS planning fairer and easier to understand for Autistic participants. Whether it succeeds will depend not only on how support needs are assessed and budgets calculated, but on whether the assessment captures support need as it is lived, whether participants can see and correct how their budget was calculated, whether plans preserve the supports that sustain their safety and participation, whether informal support is assumed or agreed, and whether the rules respond quickly when an Autistic person’s circumstances change.

The Alliance supports a more consistent national approach, but consistency must not be achieved at the expense of individual need. Assessments must distinguish independent capacity from functioning made possible through existing supports; budgets must be explainable and capable of individual adjustment, including where assumptions about informal support do not reflect what families and other supporters are willing and able to provide and sustain; and the consolidation of NDIS support categories must preserve the functions of existing supports without creating unintended gaps or additional barriers to access. Participants must also have accessible opportunities to verify assessment findings, correct errors and obtain timely consideration of newly identified support needs.

The Alliance’s 14 recommendations and six triggered safeguards provide a practical approach to managing these risks. Rather than requiring every safeguard for every participant or delaying reform until every issue is resolved, they identify when additional scrutiny or intervention is needed, who can initiate it, what action should follow and how outcomes should be monitored so that government knows whether they are working. Particular attention is required where protective supports are reduced, standardised budget assumptions do not reflect assessed need, or participants cannot readily access an appropriate support. Supported by published worked examples, a clear report and plan, and outcome data by cohort, this approach allows implementation to proceed with confidence while correcting problems early.

The Alliance welcomes opportunities to apply its collaborative testing approach to the exposure drafts of the eight rules; test autism-specific worked examples and templates with the department and the NDIA; undertake collaborative testing with Autistic people, families and relevant stakeholders; and discuss any aspect of this submission.

Contact: chair@australianautismalliance.org.au Jenny Karavolos, Independent Co-Chair, Australian Autism Alliance | jenkaravolos@outlook.com Tade A, Senior Policy Officer, Australian Autism Alliance | temiediting@gmail.com

Attachment A: What Autistic Australians have told us and what the evidence shows about assessment, budgets and supports

The Alliance’s recommendations are informed by Australian autism community evidence gathered over several years, including the national consultation of more than 3,800 Autistic people, families and carers undertaken by Australian Catholic University for the Senate Select Committee on Autism, the Alliance’s community consultation for its March 2026 submission on the first stage of the new framework planning rules, and the Australian and international research relied on in the Alliance’s recent submissions. This attachment summarises the evidence most relevant to the support needs assessment, the budget method and the NDIS supports rules.

1. Scale and relevance

Autistic people are the largest primary disability cohort within the NDIS. As at 31 March 2026, 338,099 active participants had autism recorded as their primary disability, approximately 44 per cent of active participants.5 Participants aged 18 and over will begin moving to new framework planning from April 2027, with the transition expected to be complete by December 2030.1 Primary disability data do not capture Autistic participants whose primary disability is recorded differently. The scale and diversity of the Autistic population warrant an explicit autism lens in the testing, implementation and monitoring of the new rules.

2. What the autism community told the Alliance about new framework planning

For its March 2026 submission the Alliance ran a community pulse consultation aligned with the four step planning framework. Five themes emerged: transparency and explainability are essential; human oversight and professional expertise must remain central; participants need meaningful opportunities to review and correct assessments; flexibility and participant choice must be preserved; and communication and accessibility remain critical.6 Respondents said:

‘I don’t want ai involved in this process, there should always be human oversight and control for human needs.’ (community respondent, February 2026)

‘Plan variations are rejected without people knowing why or what evidence is needed.’ (community respondent, February 2026)

‘Autism is a lifelong condition… why do you have to reassess it and go through this stressful process over and over again.’ (community respondent, February 2026)

‘Flexible should mean flexible and not restricted’ (community respondent, February 2026)

One respondent described how ‘selective mutism, high masking and complex trauma create huge challenges in disclosure and trust with people who assess me’.6 These themes map directly to the recommendations in this submission on adjustments, report correction, budget explanation and plan variations.

3. Context, masking and fluctuating capacity

The World Health Organization International Classification of Functioning, Disability and Health, on which the I-CAN is based, treats environmental factors as part of functioning and disability: functioning changes when environments change, independently of impairment.25,8 The National Autism Strategy recognises that environments, structures and practices can create barriers for Autistic people and that support needs vary with circumstances and environments.26

The Senate Select Committee on Autism reported that 47.5 per cent of Autistic adults sometimes felt unable to leave home because of fear of negative reactions, and 41.4 per cent reported experiencing discrimination or stigma.7

Camouflaging, the conscious or unconscious masking of Autistic characteristics, is effortful and costly, with consequences including exhaustion.9 A systematic review found that camouflaging is measurable and that higher camouflaging is associated with poorer mental health.10 Autistic women report more camouflaging than Autistic men, which makes under-recognition in a conversational assessment a gendered fairness issue.27 Autistic burnout, now characterised in Australian research, involves chronic exhaustion, loss of skills and reduced tolerance to stimulus arising from cumulative stress and the demands of masking.28,11,12 Co-occurring mental health conditions are common in autism.29 For a support needs assessment, the implication is that a single conversation will often see the mask, or the burnout, rather than the person’s usual support needs, which is why multiple sources of evidence, adjustments and replacement assessment triggers matter.

4. Informal support and family capacity

The Senate Select Committee reported that 67.5 per cent of Autistic adults and 73.4 per cent of parents and carers felt socially isolated, and that 34 per cent of Autistic NDIS participants aged 15 to 24 and 41 per cent of those aged over 25 had no friends other than family or paid staff.7 Many Autistic adults therefore depend on a small number of family members for prompting, coordination, transport and emotional regulation, and that support is often provided at real cost to the family. Where a budget method offsets funded support against informal support, the durability of that support and the willingness of the people providing it are central to whether the resulting budget is safe. This is the basis for Recommendation 6 and triggered safeguard 4.

5. The assessment instrument

The core needs assessment is based on a modified version of the I-CAN version 6.1 Its developer, the Centre for Disability Studies, describes the I-CAN as a holistic support needs assessment tool for people with disability aged 16 and over, based on the ICF, developed and researched in Australia, and validated for people with disability aged 16 and over.8 In the evidence review for its 2026 Senate inquiry submissions, the Alliance did not find published autism-specific validation, inter-rater reliability or test-retest research for the I-CAN.30 Members of the NDIA’s assessments and budgeting co-design working group have asked how the tool will capture fluctuating and episodic needs and ‘What will be the result of neurotypical people assessing Autistic people?’16 Australia’s experience with independent assessments, which the Joint Standing Committee on the NDIS found may not be appropriate for certain cohorts,31 shows why publishing testing results by cohort, and providing clear routes to correct individual assessments, will build confidence in the new approach.

6. Sensory and safety needs

Hyper- or hyporeactivity to sensory input, or unusual interest in sensory aspects of the environment, is one of the diagnostic criteria for autism in the DSM-5-TR.20 Evidence on noise-reducing headphones is limited but relevant. In a single-subject study of six Autistic children aged 8 to 16, skin conductance measures of physiological arousal fell significantly between baseline and the first phase in which the children wore noise-attenuating headphones.21 In a preliminary study of 21 Autistic children aged 4 to 16 with auditory hyper-reactivity, earmuffs produced a statistically significant improvement in goal attainment, while noise-cancelling headphones showed a smaller positive effect that did not reach statistical significance.22

The evidence supports individual assessment of whether a hearing protection product meets a particular person’s sensory needs. It does not support either universal funding or a categorical exclusion.

On safety, a study of more than 1,200 Autistic children in the United States found that 49 per cent had attempted to elope at least once after age four, that 53 per cent of those who eloped went missing long enough to cause concern, and that close calls with traffic and drowning were reported for 65 per cent and 24 per cent respectively of children who went missing. Fifty-six per cent of parents reported elopement as one of the most stressful behaviours they managed.23,24

7. Replacement supports

As at 17 July 2026, 11,051 replacement support requests had been received: 5,545 approved, 1,995 refused, 1,439 invalid and 2,072 pending, with 1,951 in progress. The most requested items were tablets, accessibility and communication apps, smart watches and smart phones.2 The current process allows a participant to use an item from a published list, including standard household items such as washing machines and dishwashers, instead of an NDIS support, where it delivers equal or better outcomes at the same or lower cost.19

8. What member organisations report

Member organisations that deliver assessments, therapy, positive behaviour support, adult community services and service navigation report the following from practice. An assessed shared support ratio does not necessarily translate into an arrangement that can be delivered safely, because shared support depends on compatibility between participants. Autistic people may not identify an experience as abuse, may communicate distress indirectly, or may be unable to disclose concerns in front of a family member or provider, so safeguarding cannot depend on disclosure in a guided conversation. Apparent stability is often produced by skilled and stable workers, predictable routines and environmental adjustments, and their success is not evidence that they are no longer needed. Effective therapy for many Autistic participants includes indirect work such as communication partner training, carer coaching, AAC programming and collaboration with schools and workplaces.

Implications for the new rules

Taken together, the evidence suggests four questions should sit across the implementation and monitoring of new framework planning:

• Validity: does the assessment capture support need as it is lived, across settings and over time and with the supports in place made visible, and are testing results for Autistic participants published?
• Explainability: can each participant see how their assessed needs became their budget, including any informal support assumption, and correct what is wrong?
• Responsiveness: do the rules respond quickly when circumstances change, including for participants who cannot start a request themselves?
• Equity and accountability: are outcomes examined separately for Autistic participants and other cohorts, and is there a mechanism to review a tool or rule where the data show systematic disadvantage?

Attachment B: Implementation and accountability tests for new framework planning

The Systems That Work™ approach provides a practical way of testing whether new framework planning, as it is implemented, is producing the intended outcomes for Autistic participants. The tests should be applied across the diversity of the Autistic community, including people with very high support needs, people with complex communication needs, and First Nations, culturally and linguistically diverse, LGBTQIA+ and regional, rural and remote communities. The tests below are written with an implementation lens: they ask what government should record and watch as the reform proceeds, not what must be proven before anyone moves.

Implementation tests across the planning pathway

Stage	Implementation test	Example indicators
Assessment	Does the assessment capture support need across settings and over time, with the supports in place made visible; are requested adjustments provided; and are testing results for Autistic participants published?	Adjustments requested and provided; replacement assessment requests and outcomes by cohort; testing results by cohort
Report and correction	Can participants understand their report, correct errors before the budget is calculated, and have disagreement recorded?	Correction requests and time to resolution; proportion accepted; reviews linked to report errors
Budget	Can each participant trace assessed needs to funding; are offsets and default amounts shown; and can delegates adjust where defaults do not meet assessed need?	Budget change distribution by cohort; offsets applied; delegate adjustments; reviews on budget adequacy
Using and changing a plan	Do variations respond quickly, including urgent requests with interim funding, and can participants who cannot start a request be reached through an advocate alert?	Time to interim decision; invalid and abandoned requests; advocate alerts; repeat crisis requests
Supports rules	Are supports that Autistic participants rely on still available in practice, and does the exception pathway work for disability-related needs that fall outside the list?	Exception requests, approvals and refusals with reasons; disputes about excluded items
Accountability	Is there an identified owner for each triggered safeguard, are outcomes published by cohort, and are there predefined thresholds that trigger review of a tool or rule?	Published dashboards; threshold reviews undertaken; changes made to rules or guidance

The five Systems That Work™ lenses

Lens	Implementation question
Outcomes	Are Autistic participants’ independence, participation, wellbeing and safety improving or deteriorating after moving to a new framework plan, measured against their own circumstances?
Safeguarding	Are protective supports being identified and funded; are urgent changes being handled in time; and are crises, carer breakdown and restrictive practices increasing for any group after transition?
Equity	Are assessment, budget and plan change outcomes examined separately by disability cohort, age, gender, communication profile, cultural background and geography, and is any disparity explained and acted on?

Lens	Implementation question
Learning, accountability and correction	Are baselines established, outcomes published and thresholds in place, and is there authority to adjust an assessment component, budget rule or support rule where the evidence shows systematic harm?
Voice and participation	Have Autistic people, families and autism representative organisations shaped the testing, templates and communication; do participants report that they were heard and could understand their report and budget?

These lenses are supported by a triggered safeguard test: where a trigger in section 2 occurs for a participant, is the safeguard activated, recorded and resolved within its published timeframe, and does the data show it is working? The ultimate test should be:

Did new framework planning assess Autistic participants as they actually live, give them a budget they could understand and correct, and respond quickly enough when their circumstances changed?

Attachment C: Detailed comments on the draft NDIA templates

This attachment sets out the Alliance’s detailed comments on the draft support needs assessment report and draft participant plan published with the consultation.3,4 The Alliance would welcome the opportunity to test revised versions with Autistic participants.

Part 1: Draft support needs assessment report

Section	Observation	Suggested change
Covering letter: ‘What you need to do’	Tells the participant to contact the NDIA if they think there are errors, but gives no timeframe, does not say whether errors will be corrected before the budget is calculated, and does not mention help from a supporter or advocate.	Offer a supported verification conversation and sufficient time to consider the report before findings are used for budget determination. State a defined correction period before the budget is calculated, explain how to get help, and explain that unresolved disagreement will be recorded with the report.
Covering letter	States that the report ‘replaces the previous one we shared with you’, which will confuse participants receiving their first report.	Include this sentence only where a report is being replaced.
1. Your support needs assessment	Records assessor, dates, attendees and location, but not the adjustments requested or provided.	Add a field recording adjustments requested at booking and on the day, and whether each was provided.
About you: informal supports	The entry ‘Your main informal support: Work or study full time’ is unclear, and the report does not say how informal support will be used in the budget.	Describe who provides informal support, what they do, how often, whether it is sustainable and agreed, and that it may affect the budget.
About you: communication	A single statement (‘You do not need support with communication’) does not capture communication that varies with stress, sensory load or setting.	Replace with a communication profile: preferred methods, AAC, processing time, situations in which communication changes, and adjustments needed.
Your support needs: scores	Frequency (0 to 3) and level of support (0 to 4) scores are shown without explanation.	Add a plain language key and explain how the scores are used to work out the budget.
Your support needs: narrative	Records prompting and supports in place, which the Alliance supports, but does not consistently record what happens if support is reduced, how needs vary over time, or recovery time.	For each domain, record what enables the activity, what it costs the person to sustain, what happens without the support, and how the need varies.
Your support needs: domains and narrative	The domains and examples may not consistently identify executive functioning, motor planning, proprioception, auditory processing, self-regulation, communication across environments and the support required to sustain everyday functioning	Require assessors to explore and record these needs where relevant, including preparation, prompting, supervision, environmental adjustments, co-regulation and recovery. Clarify how needs that span multiple domains are captured without being omitted or counted twice
Missing fields	There are no fields for sensory and regulation needs, masking or presenting differently in unfamiliar settings, protective supports, or the evidence considered.	Add structured fields for each, including a list of all evidence considered and the weight given to it.

Section	Observation	Suggested change
Your targeted support needs	Statements that information ‘did not meet our requirements’ do not say what was missing or what to do next.	Say what was missing, how and by when it can be provided, who pays for any required report, and that other information was still considered.
Assessor’s comments	The assessor ‘usually won’t need to complete this section’ where recommendations are funded.	Require completion whenever a professional’s recommendation, or the participant’s own account, is not reflected in the outcome.
Behaviour support outcome	Records support ratio and whether regulated restrictive practices are likely, and accepts a family member’s written account as evidence, which is welcome.	Where restrictive practices are possible, record behaviour support practitioner input and link to the triggered safeguard for an increase in restrictive practices.
2. Your assessed supports	Lists ‘Daily Supports (flexible) and ‘Travel and transport arrangements (flexible)’, which do not match the 18 categories, and private vehicle transport is a stated category.	Use the category names in the rules and show whether each is flexible or stated.
3. How to use your report	Explains how to share the report but not how to correct it or request a replacement assessment.	Add how to correct the report, request a replacement assessment, and get help from a supporter or independent advocate.
General	Contains minor typographical errors (for example ‘did not\ meet’ and ‘fold it an put it away’).	Correct before release and test the report with Autistic participants.

Part 2: Draft participant plan

Section	Observation	Suggested change
1. Your NDIS budget overview	Total, flexible and stated funding are shown clearly, but not how they were worked out.	Add a ‘How your budget was worked out’ section linking assessed needs to each category and showing any offset, adjustment or default amount.
Flexible funding with restrictions	Gives a one line reason for the restriction and no information on how to have it reviewed.	Give reasons tied to the assessment and explain how to request a review or variation of the restriction.
Requirements	Requires a registered provider for support coordination.	Explain why, and what the participant should do if no suitable registered provider is available.
Category names	Uses ‘low-cost assistive technology’, while the rules use ‘Assistive technology - Other’.	Use the category names in the rules consistently.
Flexible and stated funding: access to new supports	The plan describes funding restrictions but does not explain how a participant can obtain a newly identified stated support after approval, or clearly distinguish flexibility within a category from flexibility across categories	Explain what can be purchased within each flexible category, when cross-category use is permitted, and how to request a newly identified stated support through a proportionate plan variation. Include evidence requirements, decision timeframes, contact details and review rights, without automatically requiring a full reassessment

Reference list

1. Department of Health, Disability and Ageing. (2026). New Framework Planning Rules: consultation paper, August 2026 (version updated on the Consultation Hub in October 2026). (link)
2. Department of Health, Disability and Ageing. (2026). NDIS Supports Transitional Rules: consultation paper, August 2026. (link)
3. National Disability Insurance Agency. (2026). Draft support needs assessment report for new framework planning. (link)
4. National Disability Insurance Agency. (2026). Draft participant plan for new framework planning. (link)
5. National Disability Insurance Agency. (2026). NDIS Quarterly Report to disability ministers, Q3 2025-26 and associated appendices, reporting period ending 31 March 2026.
6. Australian Autism Alliance. (2026). Submission to the Public Consultation on NDIS New Framework Planning Rules, 6 March 2026. (link)
7. Senate Select Committee on Autism. (2022). Services, support and life outcomes for autistic Australians. Parliament of Australia, Canberra: Chapter 3, paragraphs 3.42 to 3.44; Chapter 6, paragraphs 6.105 to 6.107 and 6.146 to 6.150. (link)
8. Centre for Disability Studies. About the I-CAN (Instrument for the Classification and Assessment of Support Needs). (link)
9. Hull, L., Petrides, K. V., Allison, C., Smith, P., Baron-Cohen, S., Lai, M.-C., & Mandy, W. (2017). “Putting on my best normal”: Social camouflaging in adults with autism spectrum conditions. Journal of Autism and Developmental Disorders, 47(8), 2519-2534. (link)
10. Cook, J., Hull, L., Crane, L., & Mandy, W. (2021). Camouflaging in autism: A systematic review. Clinical Psychology Review, 89, 102080. (link)
11. Higgins, J. M., Arnold, S. R. C., Weise, J., Pellicano, E., & Trollor, J. N. (2021). Defining autistic burnout through experts by lived experience: Grounded Delphi method investigating #AutisticBurnout. Autism, 25(8), 2356-2369. (link)
12. Arnold, S. R. C., Higgins, J. M., Weise, J., Desai, A., Pellicano, E., & Trollor, J. N. (2023). Confirming the nature of autistic burnout. Autism, 27(7), 1906-1918. (link)
13. Department of Health, Disability and Ageing. (2026). New framework planning: working out a reasonable and necessary budget for a participant, fact sheet. (link)
14. Department of Health, Disability and Ageing. (2026). New framework planning: plan variations and reassessments, fact sheet. (link)
15. Department of Health, Disability and Ageing. (2026). New framework planning: support needs assessment fact sheet. (link)
16. National Disability Insurance Agency. (2025). Assessments and budgeting co-design working group meeting, December 2025. (link)
17. Australian Law Reform Commission. (2014). Equality, Capacity and Disability in Commonwealth Laws, ALRC Report 124. (link)
18. Department of Health, Disability and Ageing. (2026). New framework planning: NDIS supports, fact sheet. (link)
19. National Disability Insurance Agency. What a replacement support is (page updated 19 June 2026). (link)
20. American Psychiatric Association. (2022). Diagnostic and Statistical Manual of Mental Disorders, fifth edition, text revision (DSM-5-TR): autism spectrum disorder, criterion B4; and What is autism spectrum disorder? (link)
21. Pfeiffer, B., Stein Duker, L., Murphy, A., & Shui, C. (2019). Effectiveness of noise-attenuating headphones on physiological responses for children with autism spectrum disorders. Frontiers in Integrative Neuroscience, 13, 65. (link)
22. Ikuta, N., Iwanaga, R., Tokunaga, A., Nakane, H., Tanaka, K., & Tanaka, G. (2016). Effectiveness of earmuffs and noise-cancelling headphones for coping with hyper-reactivity to auditory stimuli in children with autism spectrum disorder: A preliminary study. Hong Kong Journal of Occupational Therapy, 28, 24-32. (link)
23. Anderson, C., Law, J. K., Daniels, A., Rice, C., Mandell, D. S., Hagopian, L., & Law, P. A. (2012). Occurrence and family impact of elopement in children with autism spectrum disorders. Pediatrics, 130(5), 870-877. (link)
24. Kennedy Krieger Institute. Nearly half of children with autism wander or ‘bolt’ from safe places (summary of Anderson et al., 2012). (link)
25. World Health Organization. International Classification of Functioning, Disability and Health (ICF). (link)
26. Australian Government. (2025). National Autism Strategy 2025-2031. (link)
27. Hull, L., Lai, M.-C., Baron-Cohen, S., Allison, C., Smith, P., Petrides, K. V., & Mandy, W. (2020). Gender differences in self-reported camouflaging in autistic and non-autistic adults. Autism, 24(2), 352-363. (link)
28. Raymaker, D. M., Teo, A. R., Steckler, N. A., Lentz, B., Scharer, m., Delos Santos, A., Kapp, S. K., Hunter, M., Joyce, A., & Nicolaidis, C. (2020). “Having all of your internal resources exhausted beyond measure and being left with no clean-up crew”: Defining autistic burnout. Autism in Adulthood, 2(2), 132-143. (link)
29. Lai, M.-C., Kassee, C., Besney, R., Bonato, S., Hull, L., Mandy, W., Szatmari, P., & Ameis, S. H. (2019). Prevalence of co-occurring mental health diagnoses in the autism population: A systematic review and meta-analysis. The Lancet Psychiatry, 6(10), 819-829. (link)
30. Australian Autism Alliance. (2026). Submission and Supplementary Submission (including the Legislation to Evidence Matrix) to the Senate Community Affairs Legislation Committee inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.
31. Joint Standing Committee on the National Disability Insurance Scheme. (2021). Independent Assessments. Parliament of Australia, Canberra. (link)