Submission to the NDIS New Framework Planning Consultation: Implications for Culturally and Linguistically Diverse Communities

October 2026

Hardwick House Unit 1, 6 Phipps Close
Deakin, ACT 2600
www.neda.org.au\ policy@neda.org.au

Submitted to Department of Health, Disability and Ageing

October 2026

Publishing information:

National Ethnic Disability Alliance (NEDA). Submission to the NDIS New Framework Planning Consultation: Implications for Culturally and Linguistically Diverse Communities. October 2026

© This work is copyright. Apart from any use as permitted under the Copyright Act 1968, no part may be reproduced without written permission from the National Ethnic Disability Alliance (NEDA). All possible care has been taken in the preparation of the information contained in this document. NEDA disclaims any liability for the accuracy and sufficiency of the information and under no circumstances shall be liable in negligence or otherwise in or arising out of the preparation or supply of any of the information aforesaid.

Acknowledgement of Country

NEDA acknowledges the Traditional Custodians of the lands on which this report was prepared. We recognise First Nations peoples’ continuing connection to land, waters, culture and community, and pay our respects to Elders past and present.

Contact for this submission

Lara Kissin
Chief Executive Officer
National Ethnic Disability Alliance (NEDA)
Email: ceo@neda.org.au

About NEDA

The National Ethnic Disability Alliance (NEDA) is Australia’s national peak body representing people with disability from culturally and linguistically diverse (CALD) backgrounds, their families and carers. NEDA holds Disability Representative Organisation (DRO) status and advocates federally for the human rights, inclusion and equitable access of CALD people with disability across all aspects of Australian life.

Introduction and framing

NEDA welcomes the opportunity to comment on the New Framework Planning. The proposed New Framework Planning reforms change how participants’ support needs are assessed, how budgets are calculated, how plans are developed, and how they can later be changed through variation or reassessment. This submission traces this process from the Support Needs Assessment, through the identification of NDIS support categories and calculation of the reasonable and necessary budget, to the participant plan and later plan changes. It focuses particularly on the relationship between standardisation and person-centredness. Standardisation is reflected in structured assessment domains, ratings of support frequency and level, predefined support categories and rule-based budget calculations (DHDA, 20026a). Person-centredness involves more than collecting information about an individual. It also concerns whether the person’s goals, lived experience, relationships, community connections, preferences, circumstances meaningfully shape the planning process and its outcomes (Sanderson, 2000, Mansell & Beadle-Brown, 2004).

The reform has clear strengths in creating a more consistent and structured pathway from assessment to funding. The Core Needs Assessment, Personal and Environmental Circumstances Questionnaire (PECQ) and any relevant targeted assessments provide information that is then translated into the types of NDIS supports the participant is assessed as needing, which are used to help calculate funding (DHDA, 20026a). This can reduce some of the inconsistency and individual planner discretion under the old framework. The proposed process also contains important procedural safeguards. Participants can review information with the assessor, receive a copy of their assessment report and raise concerns, while the delegate separately reviews the report before the plan is developed. Replacement assessment, variation, reassessment and review processes also provide opportunities to question or change decisions at different stages (DHDA, 20026a).

At the same time, standardisation does not operate at only one stage of the process. It becomes increasingly reinforced as the participant moves from assessment to budget,

plan and later plan changes. Needs are first framed through the Support Needs Assessment, with the Core Needs Assessment organising support needs across 12 domains and recording the frequency and level of support required, alongside the PECQ and any relevant targeted assessments. Information from this assessment, the PECQ and targeted assessments is then translated into one or more of the 18 predefined support categories. These assessed categories feed into the budget methods, which use approaches such as hours and prices, funding levels, quotes, benchmarks or set amounts to calculate funding. The resulting budget then becomes a central organising feature of the participant plan, while later changes in support needs are still considered through the same assessment, support-category and budget structure (DHDA, 2006a).

This creates an interlocking sequence. Needs have to be assessable and assessed within this structure in order to be recognised and carried forward through the process. At the same time, needs are progressively standardised through quantification and classification, with each stage building on the outputs of the previous one. Standardisation is therefore cumulative rather than confined to any single stage. As the process moves forward, decisions made earlier increasingly shape what can be recognised and acted on later, including which needs can ultimately be translated into funding. This leaves less room at later stages to reconsider the person’s needs from a broader perspective.

This interlocking sequence of standardisation poses challenges for how person-centred principles are implemented. The concern is not that personal or qualitative information is absent from the new framework. The assessment necessarily relies on information from the participant about their life, circumstances and support needs. The PECQ, for example, collects information about living arrangements, informal supports, education, employment and current assistive technology, and is intended to identify individual circumstances that may affect the participant’s budget. However, much of this information is used within a defined assessment and funding structure: to assess disability support needs, determine support frequency and level, identify relevant support categories and contribute to the budget calculation (DHDA, 20026a). Personal information can therefore be extensive without necessarily playing a broader organising role in the plan. It remains less clear how person-centred information such as goals, relationships, community connections, cultural understandings and other aspects of the person’s life work together holistically to shape what support is appropriate and how the budget should help the person achieve their broader goals.

Our earlier Access Change submission questioned how the NDIS policy problem and proposed solutions were being framed (NEDA, 2026a). The present submission extends this analysis to the instruments through which the reform will operate. Lascoumes and

Le Gales (2007) argue that policy instruments are not neutral mechanisms for implementing policy objectives; they can produce effects of their own and structure policy according to their own logic (p.1). They also argue that instruments can produce particular representations of a problem and “hierarchize variables” (p.11). In New Framework Planning, person-centredness remains an explicit objective, but it is implemented through a highly standardised assessment and budgeting architecture. This may give greater weight to information that can be readily classified and quantified, while broader goals, relationships, cultural context and lived experience may have less influence on the actual budget.

In this context, a narrower form of person-centredness is reflected in the structure of the draft plan. Firstly, the proposed participant plan gives greater prominence to the total budget, funding categories, spending rules and funding periods: it places the budget overview and budget before “goals and information about you”, with goals beginning at page 10, followed by relationships and daily life (DHDA, 2026b). Participants may have greater flexibility in how they use parts of their funding, particularly through flexible funding (DHDA, 2026a, pp. 9-10), after the funding envelope has already been decided. However, the participant is increasingly positioned as a budget-holder who is expected to understand and manage funding, rather than as a person whose goals, relationships and community connections organise how the plan and budget are built. In this sense, person-centredness is expressed more through budget management and is also shifted later in the planning process, after the funding envelope has been determined. The reform therefore involves a trade-off: less scope for individualised judgement in determining the funding envelope, but more participant discretion in how parts of that envelope are used once it has been set.

This shift also places greater responsibility on participants and their families. Participants are expected to understand and manage their budget, decide how flexible funding is used, recognise when changes in their circumstances may require a plan variation or reassessment, and navigate the relevant processes. Informal support may also affect the amount of funded support, including through the proposed informal-support offset for in-home and community supports (DHDA, 2026a, p.23). These responsibilities may work well for participants with strong system knowledge, access to evidence and advocacy, and confidence in managing their plan, but they may be more difficult for those who have less access to these resources.

These issues have particular implications for CALD participants. A more consistent and rules-based process may offer some benefits by reducing variation caused by individual planner judgement and differences in participants’ capacity to negotiate. However, consistency does not automatically produce equity. As our earlier submission (NEDA, 2026a) pointed out, CALD participants may face additional barriers in understanding a

technically complex process, obtaining the medical or allied health evidence expected, explaining disability-related needs across language and cultural differences, and accessing advocacy or other support to navigate the Scheme. The key question is therefore not only whether the new framework is more standardised, but whether that standardisation can still recognise different personal, family and cultural circumstances and allow them to meaningfully influence assessment, funding and planning outcomes.

The remainder of this submission examines these issues across four parts: Support Needs Assessment; budget method rules and the draft participant plan; plan variation and reassessment; and changes to the NDIS support rules. Relevant consultation questions are addressed throughout the submission, followed by a set of recommendations.

Part 1: Support Needs Assessment

1.1 What the draft framework proposes

The new framework proposes a more standardised way of assessing support needs across participants. The Support Needs Assessment will use a modified version of I-CAN v6 and include three main components: the Core Needs Assessment, the Personal and Environmental Circumstances Questionnaire (PECQ), and targeted assessments where more specific information is needed. The assessment will record the frequency and level of support required and will then be used to produce a Support Needs Assessment Report. An NDIA delegate will review the report, and participants will receive a copy and can raise concerns about it. A replacement assessment may also be arranged where the delegate considers that another assessment is needed (DHDA. 2026a, pp.6-8)

1.2 What works well

The strongest feature of the new approach is greater consistency in how support needs are assessed. Participants will go through the same structured process, using the same domains and a common approach to recording the frequency and level of support required (DHDA, 2026a). This addresses one of the weaknesses of the old system, where planning outcomes could depend more on individual planner judgement and on a participant’s or their supporters’ ability to advocate for their needs (NDIS Review Panel, 2023, p.84). A more standardised process can therefore improve procedural consistency and make the basis of the assessment more visible.

The separate Support Needs Assessment Report is also a useful procedural safeguard. Participants will receive a written record of how their needs have been assessed and can identify concerns before or alongside the budget-setting process. (DHDA, 2026a) This gives participants a clearer opportunity to see what has been recorded about them, rather than only seeing the final funding decision. The separation between the assessor and the delegate (DHDA, 2026a) also creates an additional point of checking before the plan is approved, although the current consultation material does not clarify whether the assessor is independent from the NDIA.

The focus on functional support needs may also capture differences that diagnosis alone cannot show. People with the same diagnosis can experience very different levels of functional impact depending on their personal and environmental circumstances (NDIS Review Panel, 2023, p.84). A structured assessment of support needs can therefore provide a broader picture than relying mainly on diagnosis or impairment labels. This is one area where the new approach has the potential to be more systematic than the old planning process.

1.3 Key concerns

The main concern is the tension between standardisation and person-centredness. The old system’s reliance on individual judgement created inconsistency and could advantage participants with stronger advocacy, better evidence or greater knowledge of the NDIS (NDIS Review Panel, 2023). At the same time, this discretion provided some room to explain unusual circumstances and needs that did not fit easily within standard categories. The new approach may reduce arbitrary discretion, but it may also narrow this space for individual explanation and judgement.

The draft Support Needs Assessment Report also raises questions about how person-centred information is actually used. The “About you” section is still largely framed around disability-related needs and functional capacity, while goals are placed within particular functional domains rather than operating as an overarching part of the assessment. The main body of the report is then organised around core support needs, targeted support needs and the resulting categories of NDIS supports (DHDA, 2026c). This gives the impression that functional capacity and quantified support needs are doing most of the work in the assessment.

The role of the PECQ within this process is not clear. Some PECQ-type information appears in the “About you” section and some personal information is also reflected across the Core Needs Assessment domains (DHDA, 2026c). However, the report does not clearly show how this information affects the frequency and level of support assessed, or how much weight personal and environmental circumstances have in the

final assessment. This makes it difficult to see how qualitative information actually influences the outcome.

The replacement assessment process also needs more clarity. Participants can raise concerns about the assessment process or their report, and the NDIA delegate will discuss these with them and decide whether a replacement assessment is needed. However, the circumstances for arranging a replacement assessment are still being developed (DHDA, 2026a). It is also unclear how concerns that may not require a full replacement assessment, such as factual errors or misunderstandings in the report, will be dealt with before the report is used to calculate the budget.

1.4 Implications for CALD participants

Our earlier submission has argued that a standardised assessment does not remove the social, institutional and cultural barriers that already affect CALD communities’ access to the NDIS (NEDA, 2026a). Participants may enter the same process with very different levels of English proficiency, system knowledge, access to advocacy and access to formal evidence (NEDA, 2026; NDIS Review Panel, 2023, pp.82-83). A process can therefore be consistent in procedure while still producing unequal outcomes if some participants are less able to understand the questions, explain their needs or provide the evidence that the assessment expects.

Targeted assessments may be one point where these existing disadvantages become more significant. These assessments can require reports or other information from medical and allied health professionals (DHDA, 2026a, p.7). Some CALD participants may have poorer access to specialists, culturally appropriate services or professionals who understand their circumstances, and may therefore have less formal evidence available even where their support needs are significant (NEDA, 2026). This is also relevant for psychosocial or fluctuating disability, where evidence collected at one point in time may not fully reflect changes in need (NEDA, 2026; NDIS Review Panel, 2023, p.91).

Cultural safety has been acknowledged in earlier consultation feedback, but it is not yet clearly built into the proposed assessment process. Previous feedback called for assessments that are culturally safe, trauma-informed and person-centred, and the Government response says this feedback has been shared with the NDIA (DHDA, 2026d, p.2). However, the current material does not explain how cultural background, language, different understandings of disability or culturally shaped ways of describing need will be taken into account when support needs are assessed and rated. This is particularly important in a standardised assessment that relies on structured questions and quantified ratings.

The standardisation process also makes the replacement assessment pathway particularly important for CALD participants. If a participant has misunderstood a question, relied on an interpreter, or had their cultural context misinterpreted, this should not simply become part of the quantified assessment and then flow into the budget. The current material does not yet make clear how these kinds of problems can be identified and corrected before funding is determined.

Part 2: Budget method rules and draft participant plan

2.1 What the draft framework proposes

The budget method translates the Support Needs Assessment into the amount of funding in the participant’s plan. The assessment will identify which of the 18 categories of NDIS supports are relevant to the participant, and the relevant categories fall within either flexible or stated funding. Different categories will then use different calculation methods, including estimated support hours, relative funding levels based on assessed need, quotes or benchmarks, policy-set funding levels, and single funding amounts where eligibility is established (DHDA, 2026e). Adjustments may also be made for particular circumstances, and the length of the plan is taken into account before the NDIA delegate approves the final plan (DHDA, 2026a, pp.9-10).

2.2 What works well

A procedural strength of the budget method is that the link between assessment and funding becomes more structured. Instead of relying heavily on individual planner judgement about each requested support, the rules set out how different types of funding are to be calculated (DHDA, 2026a; DHDA, 2026e). This can improve consistency across participants and make the broad logic of the funding process easier to follow. In this sense, the new approach provides a clearer procedural pathway from assessment to budget.

The proposal also gives participants more flexibility after the budget has been set. More funding is intended to sit within the flexible budget, allowing participants to move funding between eligible supports according to their changing priorities and needs within that budget. Plans may also last for up to five years, which could reduce the need for frequent full planning processes (DHDA, 2026a, p.9). These changes can increase choice in how an approved budget is used, particularly where needs change over time.

2.3 Key concerns

The first concern is that the budget method appears to rely mainly on the quantifiable parts of the Support Needs Assessment. The assessment records variables such as the frequency and level of support (DHDA, 2026c), and the budget methods then translate assessed need into hours, funding levels, quotes, benchmarks or set amounts (DHDA, 2026e, pp.3-4). Because the role of person-centred and qualitative information is already unclear in the Support Needs Assessment Report, this uncertainty is carried into the budgeting process. The more the budget method relies on quantified assessment outcomes, the more important it becomes to know how the person’s circumstances, goals and qualitative perspectives have influenced those outcomes in the first place.

This shift towards a more budget-centred approach is reflected in the NDIS Act itself. Under the old framework, section 34 of the NDIS Act 2013 focuses on whether individual supports are reasonable and necessary, including whether they help the participant pursue their goals and aspirations (NDIS Act 2013 (Cth), s34). Under the new framework, the focus shifts to a “reasonable and necessary budget” in sections 32D-32K (NDIS Act 2013 (Cth), ss32D-32K). The Act uses this term repeatedly, but it does not clearly explain what makes the overall budget reasonable and necessary. Instead, it directs the calculation of funding amounts to information from the support needs assessment and methods specified in the NDIS Rules (NDIS Act 2013 (Cth), s32K). This approach may shift attention from what individual supports a person needs towards how their assessed needs are translated into an overall reasonable and necessary budget.

This shift also changes where choice and discretion sit in the planning process. Under the old framework, delegates had more scope to exercise judgement when deciding what supports and funding were reasonable and necessary for an individual participant (NDIS Act 2013 (Cth), s34). Under the new framework, funding amounts will be more constrained by standardised budget rules (NDIS Act 2013 (Cth), s 32K; DHDA, 2026e). Participants may therefore have less scope to influence how much funding is allocated, even though they have more flexibility to decide how parts of that funding are spent once the budget has been set. In this sense, the reform may increase flexibility in spending while reducing individualised judgement in setting the budget.

The treatment of informal supports in the consultation material raises a further concern about how family care is built into the funding calculation. The policy table for In-home and Community Supports refers to an informal-support offset based on the frequency and durability of informal support (DHDA, 2026a, p.23). This means that existing support from family or carers may reduce the amount of funded support calculated

through the budget method. This raises concerns that current family involvement may be treated as an indication that families can continue providing the same level of support, even where that support may not be sustainable.

These issues are also reflected in changes to the structure of participant plans over time. Earlier plan formats placed greater emphasis on the person, including their life, relationships, community connections and goals, before setting out funded supports (NOFASD, 2020). A more recent NDIA example plan has already given greater prominence to funding (NDIA, 2024a), and the proposed new framework plan takes this further by starting with the total budget, flexible funding and stated supports, followed by detailed information about funding categories and how the budget can be used. Goals, strengths, relationships and daily life appear later (DHDA, 2026b).

This change weakens the visible connection between the person’s goals and their funding. In the earlier sample plan, goals help organise the plan and the funded supports are situated within the person’s broader life and aspirations (NOFASD, 2020). In the proposed plan, goals remain and can be broadly defined by the participant, but their connection to the calculation and structure of the budget is much weaker (DHDA, 2026b). Person-centredness is therefore increasingly expressed through flexibility in how funding can be used, rather than through a visible connection between the person’s goals and how funding is determined.

This shift is also reflected in how relationships and informal supports are presented. The earlier sample plan encourages a broader description of the person’s relationships, community connections and everyday life (NOFASD, 2020). In the proposed plan, informal, community and mainstream supports are recorded more systematically through information such as the type and frequency of support (DHDA, 2026b). This may be useful administratively, but it can also make relationships appear more as inputs into the funding process.

The proposed plan therefore also reflects a different assumption about the participant’s role. In the earlier sample plan, the participant is presented more as a person whose goals, relationships and everyday life organise the plan. In the proposed plan, the participant is increasingly positioned as an informed budget-holder who exercises choice and control through financial allocation decisions. This can be empowering where the participant has the knowledge and confidence to use the flexibility, but it also assumes a level of plan, financial and system literacy. The prominence of budget amounts, funding categories, spending rules and funding periods across the plan reinforces this budget-management focus.

2.4 Implications for CALD participants

For CALD participants, disadvantage that occurs during the assessment stage may be carried directly into the budget. The budget method largely works from the assessed support needs and the categories generated through that process (DHDA, 2026a; DHDA, 2026e). If language, cultural context, limited evidence or misunderstanding has already affected the assessment outcome (NEDA, 2026), the budgeting stage does not create a strong new opportunity to reconsider those circumstances. Standardised budget rules may therefore reproduce an earlier disadvantage.

The proposed default amount for community supports (DHDA, 2026a, p.23) provides a concrete example of this equity issue. A default amount may improve consistency, but not necessarily produce equitable funding. For some CALD participants, disability-related community participation needs may be affected by language, cultural or social circumstances (NEDA, 2026b), and these may increase the amount or type of support required to participate effectively. It is currently unclear how the default amount will respond where these circumstances create additional support needs.

The informal-support offset may create a further risk for CALD families. In some families, substantial care may already be provided where culturally responsive services are limited or other support options are difficult to access (NEDA, 2026b). Existing family involvement does not necessarily mean that family members have the capacity to continue providing it. If current family care is treated as evidence that less formal support is required, the budget method may reinforce existing caring responsibilities rather than recognising the pressure they place on the family.

The greater emphasis on budget management may also affect participants differently once the plan is approved. Flexible funding gives participants more choice, but making effective use of this flexibility requires them to understand funding categories, spending rules, funding periods and the distinction between flexible and stated supports. Participants with limited English or less familiarity with the NDIS may therefore have less practical capacity to use it effectively (NEDA, 2026b).

Part 3: Plan variation and reassessment rules

3.1 What the draft framework proposes

The new framework provides two main ways to change a plan after it has been approved. A plan variation changes a specific part of an existing plan and is intended for more targeted or shorter-term changes. A plan reassessment is a fuller process where

there has been a significant or ongoing change in support needs, and it involves a new Support Needs Assessment and a new plan. Because new framework plans may last for up to five years, variations are expected to be used more often so that smaller changes do not require a full reassessment. The budget method will also apply where funding needs to be recalculated as part of either process (DHDA, 2026a; DHDA, 2026f).

3.2 What works well

The distinction between a targeted variation and a full reassessment is useful because not every change should require the whole plan to be recreated. A smaller change to one part of the plan can potentially be dealt with more quickly and with less burden for the participant, while a full reassessment is reserved for more significant or ongoing changes in support needs. This is particularly important if plans are going to last for up to five years, because participants need a practical way to respond to changing circumstances during that period.

3.3 Key concerns

The draft plan provides examples of circumstances participants should report to the NDIA, but it does not clearly explain what may happen after a change is reported (DHDA, 2026b, p.16). In particular, it does not explain the difference between a plan variation and a plan reassessment, or when each pathway is likely to apply. Participants may find it difficult to understand what process to expect when their circumstances or support needs change.

3.4 Implications for CALD participants

For CALD participants, this lack of clarity may create additional difficulty where English proficiency, system literacy or access to advocacy is limited. If participants do not understand the difference between variation and reassessment, they may not know what process to expect, what information is relevant or whether a new Support Needs Assessment will be required. This creates an additional layer of system knowledge that participants need in order to respond effectively when circumstances change. This concern is consistent with existing evidence that some CALD participants have experienced difficulty using their NDIS plans because of limited understanding of how the Scheme and their funding can be used (NEDA et al., 2021, p.74).

The process also places responsibility on participants to recognise and describe changes in a way that fits NDIS requirements. Changes in family circumstances, informal care arrangements, housing, employment or disability support needs may be understood and described differently across cultural and family contexts (NDIA, 2024b,

p.15). A participant may experience a significant change without necessarily knowing that it is something the NDIA expects to be reported, or without knowing how to explain it in a way that leads to the appropriate pathway.

The risk is therefore not only misunderstanding the rules, but also delaying the reporting of important changes. Where communication barriers or limited familiarity with the NDIS already exist (Lai et al., 2024), participants may remain in a plan that no longer meets their needs or enter a process without fully understanding what it involves. This is particularly important under longer plans as being able to use variation and reassessment becomes important for keeping supports aligned with changing needs.

Part 4: Changes to NDIS support rules

4.1 What the draft framework proposes

The proposed support rules simplify the structure by reducing the number of support categories from 36 to 18. These categories are designed to align more closely with the Support Needs Assessment and the budget method, so that assessed needs, funding calculations and support categories follow a more consistent structure. The categories also describe the type and purpose of support and distinguish between flexible and stated supports, which helps participants understand how their funding can be used. The rules also aim to make clearer what the NDIS will and will not fund, including by removing the separate replacement-supports pathway and incorporating some commonly requested items into the new support rules (DHDA, 2026a).

4.2 What works well

Connecting the same 18 support categories to the assessment and budget method creates a stronger line between what the participant is assessed as needing, how the funding is calculated and how that funding appears in the plan. This is more coherent than having a large number of categories that participants may find difficult to understand. The distinction between flexible and stated supports is also made more visible in the proposed material. The draft plan shows which funding is flexible and which funding must be used for a particular stated purpose. This provides greater transparency about how different parts of the budget can be used (DHDA, 2026b).

4.3 Key concerns

The main trade-off is that clearer categories also create a more rules-based pathway. Under the new framework, assessed needs are translated into one of 18 support

categories, and the budget method then calculates funding for those categories (DHDA, 2026a). If a need is missed, understated or not linked to the relevant category at the assessment stage, this may affect the supports and funding available later. The NDIS supports fact sheet reinforces this approach by adding that supports may be available “where there is an assessed need” (DHDA, 2026g, p.3).

Further, pooling more funding into flexible categories can increase choice, but flexibility cannot make up for an inadequate overall budget. Its practical value therefore still depends on whether the assessment and budget method have produced enough funding to meet the participant’s support needs.

Removing the replacement-supports pathway creates a further concern about less common alternatives. Moving commonly requested items into the new support rules may make those items easier to access. However, the current replacement-supports process allows a participant to seek an alternative support where it can replace existing NDIS supports at the same or lower cost and provide the same or a better outcome (NDIS Act 2013 (Cth), s10(6)). It is not clear how less common or emerging alternatives will be considered if this pathway is removed under the proposed reforms.

4.4 Implications for CALD participants

The inclusion of interpreting and translation as a specific support category is a positive change for CALD participants. However, participants should not have to rely only on their individual funding to understand the NDIS itself. The new rules, examples and explanations should also be available in translated and accessible formats. Otherwise, participants with limited English may still face difficulty understanding how the categories apply to their own plan and how their funding can be used.

For CALD participants, removing the replacement-supports pathway may reduce flexibility where a less common alternative better fits their cultural, family or community circumstances. If the new rules mainly accommodate commonly requested replacement items, some CALD participants may have less scope to use an alternative support that is more appropriate to their individual circumstances.

Conclusion

The New Framework Planning reforms have the potential to improve consistency, transparency and flexibility, but these benefits need to be considered alongside the risk that standardisation becomes too dominant across assessment, budgeting and planning. The key issue is whether the new framework can retain enough space for personal, cultural and qualitative information to meaningfully influence funding

decisions from a person-centred perspective, rather than only being fitted into predefined assessment and budget structures. For CALD participants in particular, equity will depend not only on having the same process, but on whether that process is culturally responsive, accessible and able to recognise different circumstances and ways of expressing need and adjust accordingly.

Recommendations

The following recommendations aim to strengthen person-centredness, flexibility and equity in the New Framework Planning reforms. The Australian Government should:

Build specific safeguards for CALD participants into the Support Needs Assessment rules.

Section 32L(9) of the NDIS Act allows the Rules to make different provisions for different classes of participants. This should be used to support equitable assessment for CALD participants, including interpreters, culturally competent assessors, translated and Easy Read information, advocacy support and appropriate assessor matching where possible.

Require cross-cultural validation of the Support Needs Assessment before full implementation.

The modified assessment tool and scoring approach should be tested with people from CALD backgrounds to identify potential bias in questions, ratings and assumptions about disability, independence, family support and daily life, with ongoing monitoring after implementation.

Make person-centred information more clearly influential in the assessment process.

The Rules and assessment guidance should explain how PECQ and other person-centred information affects support ratings, assessed support categories and funding outcomes. The existing process for raising concerns about the assessment report should also make clear how personal or cultural circumstances that have been missed, misinterpreted or not given sufficient weight can be addressed.

Ensure standardised budget calculations adequately reflect individual needs.

Testing should examine not only whether participants with similar assessed needs receive consistent budgets, but whether those budgets are adequate across different

disability groups and individual circumstances. The budget method should include enough flexibility to respond when standard calculations do not adequately reflect a participant’s individual needs.

Only treat informal supports as available where they are willing, appropriate and sustainable.

Existing family or community support should not automatically be assumed to continue or be used to reduce funded support. The assessment should consider whether that support is voluntary, sustainable and appropriate for both the participant and the person providing it.

Ensure appropriate alternatives can still be considered if the replacement-supports pathway is removed.

The new support rules should retain enough flexibility to consider less common but appropriate alternatives where standard support options do not fit a participant’s individual circumstances, including cultural, family and community circumstances.

References

Australian Government Department of Health, Disability and Ageing. (2026a). New framework planning rules: Consultation paper – August 2026. https://consultations.health.gov.au/disability-and-carers-group/nfp-ndis-supports/user_uploads/consultation-paper—new-framework-planning_final-3.pdf

Australian Government Department of Health, Disability and Ageing (DHDA). (2026b). Draft participant plan for new framework planning. https://consultations.health.gov.au/disability-and-carers-group/nfp-ndis-supports/user_uploads/draft-participant-plan-for-new-framework-planning.pdf

Australian Government Department of Health, Disability and Ageing (DHDA). (2026c). Draft support needs assessment report for new framework planning. https://consultations.health.gov.au/disability-and-carers-group/nfp-ndis-supports/user_uploads/draft-support-needs-assessment-report-for-new-framework-planning-1.pdf

Australian Government Department of Health, Disability and Ageing (DHDA). (2026d). NDIS rules: Public consultation on new framework planning – How feedback was actioned.

https://www.health.gov.au/sites/default/files/2026-08/ndis-rules-public-consultation-new-framework-planning-how-feedback-was-actioned.pdf Australian Government Department of Health, Disability and Ageing (DHDA). (2026e). New framework planning: Working out a budget – Fact sheet https://consultations.health.gov.au/disability-and-carers-group/nfp-ndis-supports/user_uploads/ndis-new-framework-planning—working-out-a-budget—fact-sheet_final-1.pdf

Department of Health, Disability and Ageing. (2026f). New framework planning: Plan variations and reassessments. Australian Government. https://consultations.health.gov.au/disability-and-carers-group/nfp-ndis-supports/user_uploads/ndis-new-framework-planning—plan-variations-and-reassessments—fact-sheet_final.pdf

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