Submission

NDIS Supports Transitional Rules

Date: 14 October 2026

Our Commitment to First Nations Wellbeing, Culture, and Self-Determination

We stand in strong support of First Nations Australians, affirming their inherent right to self-determination, cultural preservation, and sovereignty over their land and traditions. We acknowledge that for First Nations peoples, mental health is inseparable from cultural, emotional, physical, and spiritual wellbeing, a holistic understanding maintained through thousands of years of continuous culture.

The Gayaa Dhuwi (Proud Spirit) Declaration Framework and Implementation Plan, launched in Meanjin/Magandjin (Brisbane) on the lands of the Turrbal and Jagera/Yuggera peoples where our office stands, provides a crucial 10-year roadmap.1 QAMH fully endorses this community-led approach to integrating First Nations leadership, cultural knowledge systems, and healing practices into Australia’s mental health frameworks.

QAMH is committed to supporting truth-telling as a process of acknowledging the histories, lived experiences, and ongoing strengths of First Nations peoples, particularly in the context of mental health. By confronting the impacts of colonisation, intergenerational trauma, and ongoing systemic injustices, we can better address the historical and contemporary factors affecting the mental wellbeing of First Nations individuals and communities.

In this submission, we emphasise the importance of holistic and healing approaches to mental health that incorporate the cultural knowledges, connection to Country, and spiritual practices of First Nations peoples. We are dedicated to ensuring that the principles of self-determination, cultural safety, truth-telling, and holistic health are central to the mental health initiatives and recommendations we propose. Our goal is to help build a future where mental health systems respect and respond to the unique needs and strengths of First Nations Australians.

Acknowledgement of Country

QAMH acknowledges and pays deep respect to Aboriginal and Torres Strait Islander peoples as the Traditional Custodians of the lands and waters across Australia. We honour their Elders past and present, whose knowledge, leadership, and cultural practices have sustained these lands for millennia.

Who is QAMH?

The Queensland Alliance for Mental Health (QAMH) is the peak body for community-based mental health and wellbeing services delivered by non-government organisations (NGOs) in Queensland. We represent over 100 members and stakeholders, involved in the delivery of these services.

Our purpose is to strengthen, promote, and advocate for community-based mental health and wellbeing service delivery for all Queenslanders, through direct engagement with our members, collaboration with government and statutory bodies, and active participation in policy reform at state and national levels.

QAMH maintains a formal collaboration with Community Mental Health Australia and contributes to the work of Mental Health Australia. We also work with both the National and Queensland Mental Health Commissions.

Our membership gives us direct insight into the experience of people living with mental health challenges, their families, carers, and kin, and the organisations that support them.

Recognition of Lived and Living Experience and Expertise

QAMH honours and affirms the lived and living experience of those who have experienced mental health and wellbeing challenges, suicide, and Alcohol and Other Drug use, and the essential contributions they make to the community mental health sector. We equally recognise the lived and living experience of family, carers, and kin, acknowledging their unique perspectives and contributions.

We acknowledge the courage and strength of those who bring their Lived and Living Expertise into professional spaces and affirm that expertise as an essential foundation for a responsive, effective, and human-centred sector.

Throughout this submission, we use the term “lived and living experience” to reflect that mental health challenges are often ongoing rather than historical, and “Lived and Living Expertise” where we refer to the knowledge, skills and insights that people develop through that experience. Both terms recognise that experiential knowledge is a genuine and valuable form of expertise, not simply a personal characteristic.

QAMH Contact Details

For any further information please contact:

Dr Rosa Flaherty
Chief Executive Officer
109 Logan Road, Woolloongabba QLD 4102
Email: ceo@qamh.org.au | Web: www.qamh.org.au

Definitions

Psychosocial supports are non-clinical, trauma-informed, recovery-oriented services that support people experiencing mental health challenges to live independently and safely in the community. They enable people to stay well, avoid crisis and participate in community life. By strengthening wellbeing and social participation, they also reduce pressure on hospitals and emergency services, making them a cornerstone of a sustainable mental health system.

Community-Based Mental Health Services delivered by the NGO sector
This sector occupies a unique and critical position within the broader mental health system. These services address the complex realities of distress shaped by trauma, poverty, isolation and other social determinants, providing practical support with housing, relationships, employment and social inclusion. These services are critical for:

People who are eligible for the NDIS and those who are not
Individuals facing barriers to accessing mainstream mental health services
People whose needs are significant but not primarily clinical.

Introduction

This consultation is one of a series of NDIS reform consultations released in close succession. The pace has made it difficult for QAMH members, and the people with psychosocial disability, families, carers and kin they support, to engage with each proposal and understand how the changes fit together. That difficulty is greater while psychosocial foundational supports outside the NDIS are not yet in place.

QAMH supports clearer and simpler Rules. The consultation summary states that the new categories “will not remove current types of supports”.2 In consolidating 36 categories into 18, however, the proposed drafting removes important references to psychosocial disability. Even where no change to support is intended, omitted wording creates uncertainty about how the Rules will be interpreted and applied. Under new framework planning, funding will also be grouped into these 18 categories.3 The category descriptions must therefore clearly recognise psychosocial supports, because they will be used alongside the new assessment and budget arrangements

The final Rules should give effect to the Department’s commitment by preserving access to psychosocial supports and the expertise required to deliver them. Participants should not bear the consequences of unclear drafting.

This submission responds to the consultation questions on clarity and on practical issues and unintended impacts. It proposes specific drafting changes so that the final Rules clearly recognise and protect psychosocial supports.

1. Are the proposed support categories clear? Are there any practical issues, or unintended impacts that need to be considered?

Recognise psychosocial recovery and specialist support

Current item 15, Development of daily care and life skills, expressly includes activities provided as part of psychosocial recovery supports.4 The mapping to category 10, In-home and community supports, retains daily living skill building and assistance with decision making, but does not retain that explicit psychosocial recovery reference.4 Psychosocial recovery remains named in proposed category 19 while psychosocial functioning is included in category 20.4

Current Rules	Current wording	Proposed category	Change
Item 15, Development of daily care and life skills	“including as part of psychosocial recovery supports”	10, In-home and community supports	Retains daily living skill building but omits the explicit reference to psychosocial recovery supports.
Item 21, High intensity daily personal activities	Provided by a worker with “additional qualifications and experience relevant to the participant’s complex or psychosocial needs”	10, In-home and community supports	The mapped description omits the explicit workforce requirement and psychosocial reference.
Item 16(b), Disability-related health supports	“supports for people with complex communication access needs or behaviours when accessing health or mental health services, including hospitals and in-patient facilities”	5, Disability-related health supports	Not carried into category 5. No proposed category refers to support while accessing hospitals or in-patient facilities.
Item 3(c), Assistance in coordinating or managing life stages, transitions and supports	Hospital discharge support “where there has been a change to a participant’s disability support needs prior to hospital admission”	19, Support coordination	Carried over unchanged.
Item 34, Therapeutic supports	Evidence-based therapy to “improve or maintain” functional capacity, including “psychosocial functioning”	20, Therapy supports	Psychosocial functioning retained. Description extended to therapy that will “reduce the decline” in functional capacity.

Naming psychosocial recovery under Support coordination, but omitting it from daily living skill building, risks obscuring recovery-oriented capacity building as a support in its own right. QAMH recommends restoring “including as part of psychosocial recovery supports” in proposed category 10. Guidance should include prompting, practical skill building, maintaining engagement, relationship building and supported community participation as examples where they address a participant’s disability support needs.

Psychosocial Recovery Coaching and lived experience peer support should be explicitly recognised. Mental Health Australia’s submission on NDIS Support Coordination recommends retaining Recovery Coaching as distinct from Support Coordination and describes its recovery planning, relationship building and capacity-building functions.5 It also reports that the NDIA is reviewing implementation of the role. QAMH supports drawing on that review before making changes affecting the role, and ensuring these Rules preserve access to specialist recovery support rather than assuming general coordination is an equivalent service.

Current item 21 requires high intensity daily personal activities to be delivered by workers with additional qualifications and experience relevant to complex or psychosocial needs. That requirement is not explicitly retained in the mapped category 10 description, although training in positive behaviour support is specified for intensive and complex behaviour supports.4 QAMH recommends retaining an explicit requirement for relevant worker capability, including psychosocial expertise where required.

The hospital discharge condition does not fit disability that is episodic and fluctuating. A person may need additional support to leave hospital because of a change during an admission, not only a change before it.

QAMH welcomes two changes. Transition support is extended from moving “out of” a mental health setting to moving “in and out of” one. Therapy supports retain psychosocial functioning and now include therapy that reduces decline in functional capacity, alongside improvement and maintenance.

QAMH proposes the following drafting changes.

Category	Drafting change
10, In-home and community supports	Restore “including as part of psychosocial recovery supports” in the capacity building description.
10, In-home and community supports	Include lived experience peer support among the examples of psychosocial recovery supports.
10, In-home and community supports	Retain the requirement for workers with additional qualifications and experience relevant to complex or psychosocial needs.
10, In-home and community supports	Define “assistance with decision making” as supported decision-making, consistent with Article 12 of the Convention on the Rights of Persons with Disabilities.6
10 and 20, In-home and community	Include culturally safe supports for Aboriginal and Torres Strait Islander participants, including supports delivered by

Category	Drafting change
supports and Therapy supports	Aboriginal Community Controlled Health Organisations (ACCHOs), among the examples.
5, Disability-related health supports	Restore support for people with complex communication access needs or behaviours when accessing health or mental health services, including hospitals and in-patient facilities.
19, Support coordination	Name Psychosocial Recovery Coaching as a support distinct from support coordination. Replace the discharge condition with support “where a participant’s disability support needs change, or additional support is required, in connection with a hospital admission”.

Preserve practical tenancy assistance

People with psychosocial disability may need continuing practical support to obtain and sustain accommodation. Parlett7 identifies unmet mental health needs and ineffective practice responses as factors contributing to difficulties sustaining temporary supported accommodation and premature exits.

Current item 1 covers supports that “build capacity, guide, prompt, or assist a participant to do activities for finding or keeping appropriate accommodation”, including supports to “apply for a rental tenancy or to take part in tenancy obligations in line with their tenancy agreement”. The proposed mapping moves this to category 19, Support coordination, which lists only “tenancy assistance and arranging and transitioning to new living arrangements”. The capacity building, guiding and prompting language is not carried over.

Coordinating services and providing practical tenancy assistance are distinct functions, and participants may need both. Disability-related tenancy skill building, prompting and practical assistance should be included explicitly in category 10, In-home and community supports, with coordination of housing transitions retained in category 19. Access to this assistance should not depend on whether a participant receives support coordination funding.

Item 1(b) maps to category 13, Medium term accommodation, with a narrower definition. The current Rules refer to long-term accommodation “or other supports not being ready”. The proposed definition refers only to “that accommodation” not being ready. A participant whose accommodation is ready, but whose supports are not may no longer be covered. The words “or other supports” should be retained.

Sequencing with foundational supports

Psychosocial foundational supports are not yet in place. The National Agreement on Foundational Supports commenced on 2 February 2026, with Thriving Kids, for children aged 8 and under, as its first phase.8 As at the time of writing, Queensland is the sole jurisdiction that has not signed up to Thriving Kids which commenced 1 October 2026. Psychosocial supports have been identified as next for discussion in the Foundational Supports design process, but their funding and implementation are not settled. Published funding for the Commonwealth Psychosocial Support Program extends only to 30 June 2027, shortly after new framework planning begins in April 2027.9,4

Unmet need is already substantial. In 2022-23, an estimated 230,500 people aged 12 to 64 with severe mental illness, and a further 263,100 with moderate mental illness, required psychosocial support but were not receiving it through the NDIS or other government-funded programs.10

Flexible supports

The paper proposes that most supports be flexible. Apart from tablets, smart phones, smart watches and accessibility and communication apps, it does not list which supports will be acceptable, or ‘stated’. For participants with psychosocial disability, flexibility allows support to increase during periods of distress and reduce as wellbeing improves, within the available budget and applicable spending rules. Capacity building and recovery-oriented supports should remain flexible, and the list of stated supports should be published before the Rules are finalised.

Summary of recommendations

Restore “including as part of psychosocial recovery supports” in In-home and community supports, and name Psychosocial Recovery Coaching as a support distinct from support coordination.
Explicitly recognise lived experience peer support as a psychosocial recovery support in In-home and community supports.
Retain the requirement for workers with additional qualifications and experience relevant to complex or psychosocial needs.
Retain explicit coverage of support for people with complex communication access needs or behaviours when accessing health or mental health services, including hospitals and in-patient facilities. Broaden the hospital discharge provision to cover changes in disability support needs arising during admission and additional disability-related support required to return to the community.
Include disability-related tenancy skill building, prompting and practical assistance in In-home and community supports, retain coordination of housing transitions in Support coordination, and retain “or other supports” in the definition of medium term accommodation.
Define “assistance with decision making” as supported decision-making consistent with Article 12 of the Convention on the Rights of Persons with Disabilities.
Include culturally safe supports for Aboriginal and Torres Strait Islander participants, including supports delivered by ACCHOs, in the category examples.
Confirm that capacity building and recovery-oriented supports will be flexible and publish the list of stated supports before the Rules are finalised.
Make no change to the Rules that narrows psychosocial support until psychosocial foundational supports are agreed, funded and operating in every jurisdiction.

References

Gayaa Dhuwi (Proud Spirit) Australia. (2025). Gayaa Dhuwi (Proud Spirit) Declaration framework and implementation plan 2025–2035.
Department of Health, Disability and Ageing. (2026). NDIS Supports Transitional Rules: Consultation summary. Australian Government. p.2
Department of Health, Disability and Ageing. (2026). New Framework Planning Rules: Consultation summary. Australian Government. p. 3
Department of Health, Disability and Ageing. (2026). NDIS Supports Transitional Rules: Consultation paper. Australian Government.
Mental Health Australia. (2026). Submission on NDIS Support Coordination and Connection reform.
United Nations. (2006). Convention on the Rights of Persons with Disabilities. https://www.ohchr.org/en/instruments-mechanisms/instruments/convention-rights-persons-disabilities
Parlett, M. (2025). Beyond shelter: Integrating mental health support in temporary supported accommodation (Insight Series No. 2). Anglicare Southern Queensland.
Federal Financial Relations. (2026). National Agreement on Foundational Supports. Australian Government.
Department of Health, Disability and Ageing. (2026, January 16). Commonwealth Psychosocial Support Program. https://www.health.gov.au/our-work/commonwealth-psychosocial-support-program
Health Policy Analysis. (2024). Analysis of unmet need for psychosocial supports outside of the National Disability Insurance Scheme: Final report. Department of Health and Aged Care.