Australian Psychological Alliance

Submission to the Joint Standing Committee on the NDIS of the 48th Parliament

December 2025

About the Australian Psychosocial Alliance

The Australian Psychosocial Alliance (APA) is Flourish Australia, Mind Australia (incorporating One Door Mental Health and The Haven Foundation), Neami National, Ruah Community Support, Stride Mental Health, Open Minds and Wellways Australia. We are seven of the largest and longest serving specialist providers of community managed mental health and wellbeing services in Australia. We provide s \support to over 110,000 people with mental health challenges and psychosocial disability every year. This includes expert support to around 5,800 NDIS participants with a psychosocial disability. We come together around a shared policy agenda to improve outcomes for people with mental ill-health and psychosocial disability, and a shared understanding of quality service delivery.

our members deliver Medicare Mental Health Centres, headspace programs, carer connect centres, step-up step-down services (sub-acute, short-term residential care), residential rehabilitation, supported housing, employment, suicide prevention and postvention programs, individual mental health recovery support and NDIS supports. We respond across the spectrum of need and to people in priority populations, such as LGBTIQA+ individuals, culturally and linguistically diverse (CALD) communities, Aboriginal and Torres Strait Islander people, young people and people experiencing or at risk of homelessness.

We combine evidence-based practice with service delivery wisdom to provide recovery-oriented services that support people to build their capacity to participate in society and manage their lives. We focus on personal goals, participation and living a meaningful life. This can include support to sustain a tenancy, build the skills to live independently, find fulfilling work and build social connections.

our organisations embed lived experience across our governance and service delivery. We employ a specialist cross disciplinary workforce with expertise in mental health and psychosocial disability, and s \with the technical skills to deliver recovery-focused, trauma-informed and person-centred support.

Annual Report No.1 of the 48th Parliament

Submission 22

1. Introduction

The APA welcomes this opportunity to make a submission to the Joint Standing Committee on the NDIS of the 48^th Parliament. We were pleased to meet with some Committee Members when the APA visited Parliament House in late October and talk in detail about the risks and our concerns for people with a psychosocial disability due to low and declining access to the NDIS. This decline in access is occurring when there are few other supports available to this vulnerable group.

The NDIA has responded to our concerns with statements that there has been no policy change or change to eligibility criteria and pointed to a 66% access rate over the life of the Scheme. We contend that changes to administrative processes and other structural elements, while not designed to deny access, are systematically doing so and are therefore discriminatory. Referencing the access rate over the life of the scheme is also nonsensical as this reflects the high numbers of people rolled into the scheme in the beginning, and not people seeking access now. The lack of acknowledgement of the issues raised or action to improve outcomes for this vulnerable group of people is troubling.

This submission highlights issues associated with the implementation, performance and governance of the NDIS; with a focus on the access process. A copy of the report is attached. The report includes case studies that highlight the personal impact of making an application to the NDIS for support.

2. About the Report

The Australian Psychosocial Alliance researched and wrote Access Denied: Psychosocial Disability and the NDIS because NDIS access was dramatically reducing for people with psychosocial disability (see page 18 onwards), and participation rates were well below predicted rates and numbers (see pages 35-36). Since the report, a further quarter of data has been released. In this quarter (Q 1 2025/26) access rates rose slightly (from 25% to 29%), but the actual number of people with a psychosocial disability seeking and receiving access decreased again and participation remains well below expected levels.

What started as an internal investigation to better understand what we were hearing anecdotally from service users and our staff about difficulties in getting access, has ended up with clear findings of: ․ systemic discrimination in the operation of the NDIS for people with psychosocial disability ․ failure of NDIA governance structures and NDIS processes to identify and respond to the particular and specific circumstances of this cohort of people.

The report makes 13 recommendations, none of which require change to legislation or eligibility criteria. They are also consistent with the many recommendations made in multiple reviews and reports dating back over more than 10 years, which are still to be implemented and for which there has been little accountability.

3. Key Findings

1. Psychosocial Disability Access to the NDIS Has Reduced Dramatically Over Recent Years

Psychosocial disability access to the NDIS has reduced dramatically over recent years. This reduction is far larger than for any other disability type. This reduction is from 66% in Q1 2020/2021 to 25% in Q4 2024/25. The rate of reduction is 62%, which is far larger than for any other disability group. The overall number of participants is also 5,500 less than Productivity Commission estimates.

2. There Have Been No Formal Changes In NDIS Eligibility Criteria Or Legislation That Can Explain Reduced NDIS Access For People With Psychosocial Disability

Annual Report No.1 of the 48th Parliament

Submission 22

The cohort is being disproportionally impacted by broader efforts to enhance “scheme integrity”; that is, reduce costs through additional, tighter and standardised (less individualised) processes. People with psychosocial disability, and people from marginalised backgrounds, experience these as increased barriers.

3. NDIS eligibility assessments continue to demonstrate poor understanding of psychosocial disability and mental health, and ignore expert assessments. Assessors frequently lack psychosocial disability understanding and training. This is producing p oor and inconsistent eligibility assessments, interactions with applicants that can be stressful and prolonged, and inconsistent and arbitrary evidence demands.

4. NDIS eligibility assessment responses are inconsistent, non-individualised and lacking in natural justice. Non-expert assessors have, on multiple occasions, identified inappropriate treatments not being tried as grounds to reject permanency. Rejection letters follow a rote format suggestive of non-individualized responses; and assessors identify inappropriate treatments that do not align with NDIS legislation on impairment, permanence or treatment, and run counter to expert opinion.

5. NDIS eligibility assessment processes create disproportionate barriers for people from marginalized backgrounds, including people with psychosocial disability. These barriers include costly medical reports, preference for (more expensive and less accessible) clinical reports over other independent assessments, duplication of ID requirements, attendance at multiple additional meetings regardless of need, value, risks or negative impact and processes which demand a certain level of cognitive capacity or education and/or access to assistance. There are few financial subsidies, including from medicare, that cover the full costs of obtaining medical or allied health reports.

6. There is a substantial risk to people with psychosocial disability because they are being excluded from the NDIS at a time when there are almost no other supports available outside the NDIS. Many important programs were defunded to fund the NDIS, but the breadth of support of these programs has not been matched by the NDIS. At a time of significant unmet need for psychosocial supports, the lack of access to the NDIS is further widening this gap. It is not reasonable that sustainability measures disproportionately impact any specific group of people— in this case, people with a psychosocial disability.

7. There is an inappropriate and inaccurate view that there are too many people with psychosocial disability in the NDIS. From scheme estimates (by the Productivity Commission and the NDIA), current scheme numbers and the trends in scheme access, people with a psychosocial disability are under-represented.

8. Most recommendations for improvements to the NDIS for people with psychosocial disability remain unimplemented, over a decade since the Scheme began.

Many government commissioned and independent reports have identified sensible recommendations to improve outcomes and experiences for people with psychosocial disability; most have not been implemented.

9. Challenges with NDIS access for people with psychosocial disability have serious negative impacts on service users and families, carers and supporters. Rejections, delay and lack of support compound the challenges people with psychosocial disability already face. Families, carers and supports similarly face substantial increased challenges, while providing emotional, practical and financial support and care. There is a ripple effect of compounding marginalisation for many, including emotional distress, financial insecurity and deterioration in health.

10. Recommendations

Please see pages 12–13 in Access Denied for more detail on each recommendation.

For immediate action:

1. Clarify eligibility assessment criteria and processes for psychosocial disability.
2. Ensure expert oversight of psychosocial disability applications.
3. Establish a new psychosocial disability working group to progress reform.
4. Set targets and timelines for psychosocial disability access that are aligned to the original Productivity Commission projections, and monitor monthly.

Short term, start now and aim to complete within 6 months: 5. Establish a psychosocial pathway to and within the NDIS. 6. Ensure psychosocial disability expertise in implementation of the new NDIS support needs assessment tool, I-CAN. 7. Monitor changes and their impact on people with psychosocial disability.

Medium term, start now and ensure progress within 12 months: 8. Improve NDIA psychosocial disability capability. 9. Improve outcomes for people with psychosocial disability within the NDIS. 10. Ensure greater psychosocial disability representation in NDIS governance. 11. Develop psychosocial disability-specific NDIS supports. 12. Create a comprehensive system of psychosocial supports outside the NDIS. 13. Integrate development of Foundational Supports with the response to unmet need.

5. The way forward

The key findings and recommendations set out a means to remedy access issues with the NDIS for people with psychosocial disability. Change is necessary and long overdue.

A imperative exists to act now, particularly given the high level of unmet need and because of concerns about Scheme sustainability. Without changes that address the significant lack of expertise in psychosocial disability, the lack of a psychosocial pathway and oversight and leadership to ensure that the Scheme is fair and equitable to all people, we are concerned that reforms – including the significant investment in a new planning tool (the I–ICAN) – will only compound the issues that we, and many others, continue to highlight.

Annual Report No.1 of the 48th Parliament

Submission 22

While our report identifies 13 recommendations that need to be progressed, we have also identified some very practical, low cost and immediate changes that would make a difference.

The following include:

• For applicants to be fully aware of any potential reasons for rejection and, with the help of their support worker or other supporters, have an opportunity to identify and clarify any misunderstandings before a decision is made. Ultimately, the assessment process should include an in-person meeting with the applicant in their environment, with a support worker present.
• Assessors should have guidance that equips them to identify and respond to a range of evidence provided by people who know and/or have supported the applicant, to assist the assessor to understand whether the person meets the criteria or not. This includes advice that Part B of the Flinders University developed Evidence of Psychosocial Disability form does not require completion by a clinician. This partly responds to difficulties in accessing (financial and practical) quality assessments from expert Occupational Therapists.
• New guidance for assessors should be issued about how to understand functional impairment, so assessors can better determine permanency, rather than focus on treatment for mental health symptoms. Assessors need to understand the interface of mental health and psychosocial disability, but that psychosocial disability can exist alongside and separate from the nature of treatment for mental illness.

These changes require issuing guidelines that direct assessors to proactively engage in a collaborative process with support workers and/or family and carers (with the applicant’s permission), to discuss and understand the evidence presented, and to be flexible with regards to the source of evidence. It should also include an immediate refresh for those undertaking assessments to understand what to expect and how to interpret the Evidence of Psychosocial Disability form.

Additionally, two immediate (and easy) changes that would make a positive difference to people’s NDIS experience would be the reinstatement of referral from external agencies to the complex support needs pathway, and for the NDIA to be directed to cease undertaking informal plan reviews for people with a psychosocial disability and for these to occur only with (written) notice and with an appropriate support worker present.

Unfortunately, access is not the only concern the APA holds about the NDIS and how it serves people with psychosocial disability. There are other issues of planning, utilisation, experience and NDIA practice that threaten positive outcomes for people with psychosocial disability. We, along with many others, also hold significant concerns about the quality and appropriateness of NDIS supports for people with a psychosocial disability, registration and pricing and market stewardship. We continue to make submissions to the Commonwealth Government and the NDIS Quality and Safeguards Commission regarding these matters; and continue to advocate for a more joined up response across the mental health and disability portfolios.

It is time for change, time for equity, and time for people with psychosocial disability to experience NDIS access differently. We hope the Committee will consider our concerns and submission; we stand ready to assist your efforts to improve the NDIS for people with psychosocial disability.

Attachment: APA Report Access Denied: Psychosocial disability and the NDIS

Contact: Kate Paterson, Policy and Engagement Advisory,

Web: psychosocialalliance.org.au

Page 6 of 6

Australian

Psychosocial Alliance

Australia’s leading providers of psychosocial support services

Access Denied:

Psychosocial Disability and the NDSI <2

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Acknowledgements

• The APA acknowledges that Aboriginal and Torres Strait Islander peoples are the Traditional custodians of the lands on which we work, and

we pay our respects to Elders past and present.

• The APA values the experience and contribution of people from all cultures, genders, sexualities, bodies, abilities, spiritualities, ages and backgrounds. We are committed to inclusion for all our clients, families and carers, employees and volunteers.

• The APA values the expertise and leadership of people with personal lived and living experience of mental health challenges and alcohol and other drug use, and families and carers as we work together to influence and transform the services and systems in which we work.

• The APA thanks all those people and organisations who generously provided their experience and advice during the development of this report.

Report team

Authors: David Threlfall, Kate Paterson, Sam Donnelly, Adele Beasley, Ellie Mckenzie, Nicola Ballenden

APA advisory group: APA CEOs and APA Policy Network

Lived Experience consultant: Terri Warner

Suggested citation

Threlfall, D, Paterson, K, Donelly, S, Beasley, A, McKenzie, E and N Ballenden 2025. Access Denied: Psychosocial disability and the NDIS, Australian Psychosocial Alliance (APA).

Front cover illustration

The Australian Psychosocial Alliance (APA) is made up of the largest specialist providers of community managed mental health and wellbeing services in Australia, providing support to over 110,000 people every year.

[D> ™ mind. Where mental wedeing tives Help, hope and purpose neami 48 OOR national onal Meath ogenmintss RAH COMMUNITY SERVICES Harriet McDougall, illustrator and lived experience team member at Mind Australia

Contents

Foreword: Participant lived experience Foreword: Carer lived experience

Executive summary

• — Key findings
• Recommendations

1. Introduction

• Whois the Australian Psychosocial Alliance?
• About this report
• Supporting organisations

2. Key findings with summaries

3. Recommendations with summaries

4. What is psychosocial disability?

5. ‘It’s taken a sharp turn’: psychosocial disability access to the NDIS 5.1 Analysis of NDIS access data 5.2 Analysis of APA organisational data on discharge to the NDIS

6. ‘It feels like system-enforced speed humps’: why is psychosocial disability access to the NDIS dropping so quickly? 6.1 NDIS rejections: poor understanding of psychosocial disability and ignoring expert assessments 6.2 Barriers to application and access 6.3 Concern for people with multiple and complex needs

7. ‘Dol even try again? What do | gain from trying to get into this system?’

The impact of reduced psychosocial disability access to the NDIS 7.1 Risk to the cohort: psychosocial disability is a real disability 7.2. Well past time for change: opportunities for reform not taken 7.3, Marginalisation and the ripple effect

8. Conclusion 8.1 Reduced psychosocial disability access to the NDIS 8.2 A false economy with a human price 8.3 Charting a path forward for psychosocial disability

References

FOREWORD

The NDIS has been a part of my life both personally and professionally for over

a decade, and I’ve always approached it with (at best) informed apprehension.

It’s a common experience for people who need mental health related support to be told that we have too much, not enough, or the wrong kind of need for support we would choose, and to have support we would not choose forced on us. The NDIS was supposed to do things differently for those of us who need disability support, but more and more it is reproducing processes that are both familiar and harmful.

| know what it’s like to submit to an intrusive, demoralising and deleterious process to have my support needs affirmed, and met. | dread each review of my NDIS plan, and have to put support in place either side of any related interaction. But | made it in. I’m an NDIS participant, and | get and use funding for support that | need. | have to fight for it every time, and it has been cut in some way almost every time, but | get it.

As this report demonstrates, people with psychosocial disability are increasingly and disproportionately being denied access to the NDIS, for reasons that have little to do with each individual applicant’s expressed or demonstrated need for non-mainstream disability support for their lifetime. The result is suffering caused by choices that powerful people make, and changes that they wont, and | dont know how to be an optimist about that.

What all of these maritime metaphors about the current state of the NDIS ignore is the fact that no one should be drowning. This report highlights the need to think about who is, and why, and how to change that.

TERRI WARNER

Terri is a nationally recognised lived experience researcher and advocate whose lifelong experiences of disability, mental distress, mental health and social care service use, and as an NDIS participant, inform all of her work. Her research explores the effects of health and social policy and the role of lived expertise in health and social care.

Australian Psychosocial Alliance

FOREWORD

Carer lived experience

I am supporting the release of this report because I want to see people with psychosocial disability accepted and for carers to be able to get the help they need to support their loved ones.

I have been a carer for approximately 26 years, and 16 of these were caring for my wife with complex mental health issues. During this time, I worked in multiple jobs, completed a Bachelor of Psychology and Social Sciences and raised my family. We used private health cover, and I tried my best not to be a blight on the system. I would have preferred to remain self-reliant.

However, after the needs of my wife became too much for me to support, I realised that being self- taliant wasnt an option anymore; I needed help.

We applied for the NDIS multiple times over five years. We needed more than what the mental health system could provide.

We submitted evidence from my wifes psychiatrist about her mental health challenges that she had experienced for almost three decades, and the toll theyd taken, the disability she now had. But they kept asking for more evidence and more paperwork that we’d already provided. The evidence requests continually changed and seemed to contradict previous advice.

We kept on being rejected.

It felt like they didnt understand psychosocial disability or mental health challenges; that she needed ongoing support day-to-day. The process was confusing and frustrating.

AI

WE ARE EXHAUSTED AND DEFEATED BY AN UNCARING AND IGNORANT SYSTEM THAT PROCLAIMS TO EMPOWER US BUT IS SHROUDED IN SO MUCH RED TAPE.

Finally, my wife was accepted into the NDIS. We received the golden ticket that was going to save our family.

However, for us, it was too late. She passed away two weeks before the notification came through.

I feel let down. I needed people who understood my situation without judgement. I needed support. My wife needed support.

I see my own journey reflected in so many carers I meet. We are exhausted and defeated by an uncaring and ignorant system that proclaims to empower us but is shrouded in so much red tape that it becomes systematic speed humps designed to bottleneck our access to the systems we are seeking assistance from.

e By sharing my story, I only hope that other people are more successful and can navigate the system easier to receive NDIS support in a more timely manner than my wife.

BRUCE

“Bruce requested that only his first name is supplied out of respect for his wifes family’s privacy.”

Access Denied: Psychosocial Disability and the NDIS

Executive summary

Access Denied: Psychosocial Disability and the NDIS shows how NDIS access has dramatically reduced for people with psychosocial disability, and participation is well below predicted rates and numbers.

People with psychosocial disability often experience high levels of social disadvantage and social isolation. They have poorer physical health and lower life expectancy. They struggle to maintain stable housing, and are overrepresented in homelessness statistics and interactions with the justice system. People with psychosocial disability need understanding, support if required—and equitable access to national support systems like the NDIS.

The federal government intends to pursue reform to ensure the NDIS is no longer the ‘only lifeboat in the ocean or the ‘only port in the storm’ A strong system of Foundational Supports—a new service system of disability supports outside individualised NDIS budgets— is an essential addition for diverse, responsive, nationally consistent access to disability supports. But it will never be a substitute for the NDIS for those who need it.

Crucially, this includes many people with psychosocial disability.

There is broad community understanding that the NDIS needs reform. But the imperative to cut costs has serious unintended consequences that are already playing out. Right now, there is no alternative system of support for those with complex mental health needs and significant disabilities, other than the NDIS. Yet people with psychosocial disability are already having their NDIS Access Denied in increasing numbers. This is occurring because internal NDIA policy and process changes are disproportionately and negatively affecting people with psychosocial disability.

Denied life-changing support, people can experience preventable decline and greater loss of capacity. Often initial denial of support ends in eventual NDIS access—after avoidable damage is done. This comes at greater cost to the NDIS and to governments. It’s a false economy with a human price.

It is time for change. People with psychosocial disability who need the NDIS, have a right to access the NDIS. This report, Access Denied: Psychosocial Disability and the NDIS, demonstrates why this problem exists and offers recommendations for a fairer path forward.

‘Shorten (2023). ‘Lifeboat: Correspondence, Quarterly Essay 92.; Butler (2025, August 20). Speech from Minister Butler, National Press Club - 20 August 2025.

Australian Psychosocial Alliance

Key findings

Psychosocial disability access to the NDIS has reduced dramatically over recent years. This reduction is far larger than for any other disability type.

• There have been no formal changes in NDIS eligibility criteria or legislation that can explain reduced NDIS access for people with psychosocial disability.

• NDIS eligibility assessments continue to demonstrate poor understanding of psychosocial disability and mental health, and ignore expert assessments.

• NDIS eligibility assessment responses are inconsistent, non-individualised and lacking in natural justice. Non-expert assessors have, on multiple occasions, identified inappropriate treatments not being tried as grounds to reject permanency.

• NDIS eligibility assessment processes create disproportionate barriers for people from marginalised backgrounds, including people with psychosocial disability.

• There is a substantial risk to people with psychosocial disability because they are being excluded from the NDIS at a time when there are almost no other supports available outside the NDIS.

• There is an inappropriate and inaccurate view that there are too many people with psychosocial disability in the NDIS.

• Most recommendations for improvements to the NDIS for people with psychosocial disability remain unimplemented, over a decade since the Scheme began.

• Challenges with NDIS access for people with psychosocial disability have serious negative impacts on service users and families, carers and supporters.

FOR IMMEDIATE ACTION

1. Clarify eligibility assessment criteria and processes for psychosocial disability.
2. Ensure expert oversight of psychosocial disability applications.
3. Establish a new psychosocial disability working group to progress reform.
4. Set targets and timelines for psychosocial disability access that are aligned to the original Productivity Commission projections, and monitor monthly.

SHORT-TERM: START NOW AND AIM TO COMPLETE WITHIN 6 MONTHS

5. Establish a psychosocial pathway to and within the NDIS.
6. Ensure psychosocial disability expertise in implementation of the new NDIS support needs assessment tool, I-CAN.
7. Monitor changes and their impact on people with psychosocial disability.

MEDIUM TERM: START NOW AND ENSURE PROGRESS WITHIN 12 MONTHS

8. Improve NDIA psychosocial disability capability.
9. Improve outcomes for people with psychosocial disability within the NDIS.
10. Ensure greater psychosocial disability representation in NDIS governance.
11. Develop psychosocial disability-specific NDIS supports.
12. Create a comprehensive system of psychosocial supports outside the NDIS.
13. Integrate development of Foundational Supports with the response to unmet need.

Key data from Access Denied: Psychosocial Disability and the NDIS

Australian Psychosocial Alliance

decrease in psychosocial disability access rates since full Scheme roll out in mid-2020.

for a clinician report to support an NDIS application.

for a copy of someone’s own medical records to support an NDIS application.

people with psychosocial disability who were estimated to be in the NDIS but are not currently getting support (using original Productivity Commission methodology).

people with long-term mental health conditions report highest levels of financial stress (per HILDA survey data).

The year that the Productivity Commission modelled psychosocial disability support within the NDIS; 2 years before the NDIS was launched.

years since the NDIS began, most recommendations for improvement for people with psychosocial disability have still not been implemented.

Introduction

This report, Access Denied: Psychosocial Disability and the NDIS, shows how access to the National Disability Insurance Scheme (NDIS) has dramatically reduced for people with psychosocial disability. The Australian Psychosocial Alliance (APA) is deeply concerned about this disproportionate reduction and the impact this is having on this cohort.

People with psychosocial disability already face significant barriers to full social and economic participation in Australian society. They often:

• experience high levels of social disadvantage
• experience high levels of social isolation
• have poorer physical health
• have lower life expectancy
• struggle to maintain stable housing
• are overrepresented in homelessness statistics, and
• are overrepresented in interactions with the justice system.

People with psychosial disability need understanding, support if required, and equitable access to national support systems like the NDIS. Access Denied highlights that such equity is at risk.

This reduction in NDIS access for people with psychosocial disability comes in the context of ongoing changes to the NDIS and significant unmet need outside of the NDIS.

Broad national agreement exists about the need to ensure the sustainability of the Scheme. The APA stands ready to contribute expertise to this effort. We understand the federal government intends to pursue reform to ensure the NDIS is no longer the only lifeboat in the ocean or the only port in the storm? A strong system of Foundational Supports—a new service system of disability supports outside individualised NDIS. budgets—is an essential addition for diverse, responsive, and nationally consistent access to disability supports. But such alternative support systems will never be a substitute for the NDIS for those who need it. Crucially, thi includes many people with psychosocial disability.

The APA is concerned that the imperative to reduce NDIS costs has serious unintended consequences that are already becoming clear. There are no alternatives to the NDIS for those with complex needs and significant disabilities. Yet people with psychosial disability are already having their NDIS access denied in increasing numbers. This disproportionate impact on people with psycosial disability is occurring despite there being no formal changes in NDIS eligibility criteria or legislation that are directly aimed at exclusion of this cohort.

Denied life-changing support, people can experience preventable decline and greater loss of function and capacity. Often initial denial ends in eventual NDIS access—after avoidable damage is done. This comes at greater cost to the NDIS and to governments. It is a false economy with a human price.

Access Denied: Psychosocial Disability and the

NDIS, explains why this problem exists and offers recommendations for a fairer path forward. The report first presents summaries of the APA’s key findings (section 2) and recommendations (section 3). Section

4 explains what psycosial disability is and how the NDIS assesses disability and functional capacity. The following sections: illustrate the reduction in NDIS access for people with psychosial disability (section 5), present an analysis of why this is happening (section 6) and detail the impact of the reduction (section 7). The conclusion calls for a cooperative federal approach to resolve this issue so people with psychosial disability can get the support they deserve.

It is time for change. People with psychosial disability who need the NDIS, have a right to access the NDIS.

Who is the Australian Psychosocial Alliance?

The Australian Psychosocial Alliance (APA) includes Flourish Australia, Mind Australia (incorporating

One Door Mental Health and The Haven Foundation), Neami National, Ruah Community Services, Stride Mental Health, Open Minds and Wellways Australia.

We are seven of the largest and longest serving specialist providers of community managed mental health and wellbeing services in Australia. All our members are not-for-profits. We provide support to over 110,000 people with mental health challenges and psychosocial disability every year. This includes expert support to around 5,800 NDIS participants with a psychosocial disability. We come together around a shared policy agenda to improve outcomes for people with mental ill-health and psychosocial disability, and a shared understanding of quality service delivery.

Our members deliver Medicare Mental Health Centres, headspace programs, carer connect centres, step-up step-down services (sub-acute, short-term residential care),

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residential rehabilitation, supported housing, employment, suicide prevention and postvention programs, individual mental health recovery support and NDIS supports. We respond across the spectrum of need and to people in priority populations, such as LGBTIQA+ individuals, culturally and linguistically diverse (CALD) communities, Aboriginal and Torres Strait Islander

people, young people and people experiencing or at risk of homelessness.

We combine evidence-based practice with service delivery wisdom to provide recovery-oriented services that support people to build their capacity to participate in society and manage their lives. We focus on personal goals, participation and living a meaningful life. This can include support to sustain a tenancy, build the skills to live independently, find fulfilling work and build

social connections.

Our organisations embed lived experience across our governance and service delivery. We employ a specialist cross disciplinary workforce with expertise in mental health and psychosocial disability, and with the technical skills to deliver recovery-focused, trauma-informed and person-centred support.

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About this report

Access Denied brings together the knowledge, data and expertise of APA service users, services, staff and leadership. It seeks to amplify the voices of people who shared their thoughts and challenges with us. Quotes throughout this report come from these conversations with NDIS participants, NDIS applicants, families, carers, supporters and APA staff - all trying to access potentially life-changing support.

In preparing this report we undertook the following activities:

• Engagement with:
• NDIS participants in APA services
• APAservice users who have had their NDIS applications rejected
• Families, carers and supporters of NDIS participants
• Families, carers and supporters of APA service users who have had their NDIS applications rejected
• Staffin APA services, delivering NDIS and non-NDIS support
• More than 50 disability advocacy organisations, disability service providers, specialist psychosocial disability service providers, homelessness service providers and social services organisations
• State, territory and national peak bodies in disability and mental health
• Federal, state and territory ministers, political advisers and public servants
• Expert consultants
• Analysis of public NDIS data
• Analysis of APA organisational data from NDIS and non-NDIS service delivery
• Analysis of government reports, other grey literature and academic literature.

The APA also sought lived experience expertise (including service users, carers, families and supporters) in the preparation of the report to ensure we called out this issue in an appropriate and meaningful way. We speak as a group of service providers that hold knowledge and expertise about the operation of the disability and mental health systems. Our engagement and writing process has sought to be true to those we support, and to highlight how the system is failing people who are seeking access to the NDIS. The APA developed Access Denied because we believe best outcomes can be achieved with a breadth of voices contributing to NDIS and mental health reform discussions. We hope this report supports the advocacy efforts of others.

Key findings with summaries

Psychosocial Disability Access to the NDIS

Key findings:

• The access rate for people with psychosocial disabilities has reduced dramatically over recent years.
• From 66% acceptance nationally in Q1 2020/21 to just 25% in Q4 2024–25 (a reduction of 62%).
• People with psychosocial disability are facing significantly lower and declining access rates compared with other disability types within the NDIS.
• There have been no formal changes in NDIS criteria or legislation explaining this decline; instead it is due to broader efforts aimed at enhancing ‘scheme integrity’ through tighter processes that disproportionately affect those from marginalized backgrounds.
• These barriers include: cost up to $1750 for GP reports, preference for psychiatrist or clinical psychologist evidence which may be less accessible than independent expert assessment, ID requirements duplicating existing government agency procedures, administrative demands requiring certain levels of education/cognitive functioning/informal support potentially discriminatory against some groups, attendance at multiple meetings regardless of need/value/risk impact.
• Assessors frequently lack understanding/training regarding psychosocial disability leading to poor inconsistent eligibility assessments interactions.

See Section 6.1 on page 26 for more information.

vi. difficulties in partaking in application processes

facts. Stigma and discrimination cannot be allowed to without a fixed address inappropriately cloud these debates.

vii. prolonged process: it takes too long to prepare

an application, and too long for a decision to be made

S E E S E C T I O N 7 . 1 F O R M O R E O N T H I S , F R O M P A G E 3 5

viii. multiple and complex needs.

S E E S E C T I O N 6 . 2 F O R M O R E O N T H I S , F R O M P A G E 2 9

8. Most recommendations for improvements to the NDIS for people with psychosocial disability remain unimplemented, over a decade since the Scheme began.6. There is a substantial risk to people with psychosocial disability because they are being excluded from the NDIS at a time when there are almost no other supports available outside the NDIS.

Regardless of multiple policy processes underway to create a system of Foundational Supports for people with psychosocial disability, or to respond to unmet mental health need, this cohort is underserved right now. Many important mental health programs in community were defunded to fund the NDIS.3 The breadth of support these former programs provided has not been matched by the NDIS, given the higher threshold for access and the individualised nature of NDIS support. And NDIS access is falling for people with psychosocial disability. The risk to this cohort is clear—the gap is widening. While it is understandable that the government would want to control NDIS growth, it is not reasonable if sustainability measures have a disproportionate impact on one particular disability group: in this case people with psychosocial disability.

S E E S E C T I O N 7 . 2 F O R M O R E O N T H I S , F R O M P A G E 3 7

9. Challenges with NDIS access for people with psychosocial disability have serious negative impacts on service users and families, carers and supporters. impact on one particular disability group: in this case Rejections, delay and lack of support compound the challenges people with psychosocial disability already face. Families, carers and supporters similarly face substantial increased challenges, while providing emotional, practical and financial support and care. There is a ripple effect of compounding marginalisation for many, including emotional distress, financial insecurity and deterioration in health.

S E E S E C T I O N 7 . 1 F O R M O R E O N T H I S , F R O M P A G E 3 5

7. There is an inappropriate and inaccurate view that there are too many people with psychosocial disability in the NDIS. A thorough analysis of the Scheme estimates, current Scheme numbers, and the trends in Scheme access all refute this view. Deeply important national policy developments should begin from understanding of the

3Hancock et al. (2019). Commonwealth Mental Health Programs Monitoring Project: Tracking transitions of people from PIR, PHaMs and D2DL into the NDIS: Final report. Community Mental Health Australia & the University of Sydney.

Recommendations

with summaries

The APA calls on the federal government and the NDIA to take immediate action to ensure fair and equitable access to the NDIS.

In recognition of the need for progressive yet urgent reforms, the following recommendations are split into three time periods: immediate, for those that can occur quickly; short-term, for those that require some more planning, and; middle-term for those that need to align with broader system change and funding decisions.

• Clarify eligibility assessment criteria and processes for psychosocial disability.

The NDIA should develop internal guidelines for eligibility assessments that give greater weight to functional capacity (what a person is able to do in their daily life) than treatment for a medical condition in determining permanency for people with psychosocial disability.

• Ensure expert oversight of psychosocial disability applications.

The NDIA should implement centralised oversight arrangements for the assessment of access applications for people with a primary psychosocial disability. This oversight should be led by people who have demonstrated experience and understanding of psychosocial disability and mental health. Such oversight is a first step towards the NDIA ensuring appropriate psychosychological disability expertise amongst staff undertaking assessment of applications from people with a psychosocial disability (recommendation 8).

• Establish a new psychosocial disability working group to progress reform.

The NDIA should establish a new psychosocial disability working group, which includes people with lived experience (service users and carers), peak bodies and specialist psychosocial disability support service providers, to provide recommendations on how psychosocial disability-specific NDIS reforms can be progressed, alongside development of Foundational Supports and efforts to meet unmet psychosocial needs.

Australian Psychosocial Alliance

• Set targets and timelines for psychosocial disability access that are aligned to the original Productivity Commission projections, and monitor monthly.

Psychosocial disability access to the NDIS is currently well below rigorous, earlier projections by the Productivity Commission and NDIA. To ensure good, equitable outcomes, psychosocial disability access must be monitored more closely, to prevent ongoing unintended consequences from reform.

• Establish a psychosocial pathway to and within the NDIS.

The federal government and the NDIA should establish a specialist psychosocial disability pathway within the NDIS, to improve access, planning, utilisation and experience for people with psychosocial disability. Pathway development should be guided by the psychosocial disability working group (once established). This pathway should be promoted through proactive outreach to encourage appropriate applications.

• Ensure psychosocial disability expertise in implementation of the new NDIS support needs assessment tool, I-CAN.

The federal government, NDIA and I-CAN developers from the University of Melbourne and the Centre for Disability Studies must ensure that the implementation of the I-CAN is appropriate and meaningful for people with a psychosocial disability, and incorporates psychosocial disability expertise.

Monitor changes and their impact on

people with psychosocial disability.

The federal government and NDIA should develop anew regime for monitoring access, impact of past and future procedural or legislative change on people with primary psychosocial disability, and the overlap between the experiences of people with psychosocial disability and people from other marginalised cohorts or with complex needs.

Improve NDIA psychosocial

disability capability.

The NDIA should improve psychosocial disability capability for NDIA staff and across NDIA processes, covering training, development, guidelines and policies. This includes reprioritising psychosocial disability within the Agency and establishing a branch dedicated to improving the outcomes and experience of people with a psychosocial disability within the NDIS.

Improve outcomes for people with

psychosocial disability within the NDIS.

After establishment of a psychosocial disability working group and a psychosocial pathway to and within the NDIS, the federal government and NDIA must ensure outcomes improve for people with psychosocial disability within the NDIS. Attention should be paid to maintaining specialist psychosocial providers within the Scheme, particularly those

with lived experience workforces. Reform must centre choice and control for participants, protecting dignity and agency, and also balancing equity, fairness and sustainability. Many relevant specific recommendations for NDIS reform for people with psychosocial disability exist already and should inform next steps (see: key finding 8, p5; section 7.2, Figure 7, p.38).

Ensure greater psychosocial disability

representation in NDIS governance.

The federal government and NDIA should ensure greater psychosocial disability representation on the NDIA Board and within the NDIA staff base, and on the NDIS Reform Advisory Committee in future.

Develop psychosocial disability-specific

NDIS supports.

The NDIA should develop psychosocial disability-specific NDIS supports, to ensure

people with psychosocial disability can exercise choice of a fit-for-purpose product within the NDIS, including psychosocial disability-specific home and living supports for people who have supported housing needs.

Create a comprehensive system of

psychosocial supports outside the NDIS.

All governments need to agree to establish a comprehensive psychosocial support response outside of the NDIS. These supports are to be community based and provide a range of supports across the spectrum of need. The Mental Health Australia Renewed Statement on Addressing Unmet Need for Psychosychological Support Outside the NDIS* provides a clear pathway.

Integrate development of Foundational

Supports with the response to unmet need.

Efforts to create a comprehensive system of psychosocial supports outside the NDIS, and to develop Foundational Supports for people with psychosocial disability outside of individualised NDIS budgets should be integrated. Although psychosocial supports will serve a larger portion of the population, there is some overlap, so policy reform efforts must ensure an integrated, responsive, accessible continuum of psychosocial supports to meet diverse need across the country.

‘Mental Health Australia. (2025). Renewed Statement on Addressing Unmet Need for Psychosocial Support Outside the NDIS.

What Is Psychosocial Disability?

Some people’s complex mental health challenges impact their daily function. Support systems like the NDIS were designed to promote greater inclusion for this group through access to appropriate individualised support. The NDIS self-care and social participation. Psychosocial disability refers to such functional limitations experienced by individuals due to a mental health condition (or conditions).

Regardless of stigma, discrimination and misunderstanding, this is a real disability. It has significant functional impacts in line with the NDIS guidelines. This means that it ‘substantially impacts your ability to do daily life activities [and] affect[s] your social life, or your ability to work and study’

Psychosocial disability is characterised by difficulties in thinking, feeling and behaving that significantly impair one’s ability to manage everyday tasks, maintain relationships, enjoy good physical health and engage in social and occupational activities. Rather than a medical understanding of the symptoms common to a mental illness, a psychosocial disability is about the impact on a person’s ability to function in daily life and participate in social activities.

PEOPLE LIKE ME NEED ONGOING SUPPORT TO LIVE INDEPENDENTLY AND STAY WELL.

As a cohort, people with psychosocial disability frequently experience marginalisation and often have multiple and complex needs. This means they face significant barriers to full social and economic participation in Australian society. They often:

• Experience high levels of social disadvantage
• Experience high levels of social isolation
• Have poorer physical health
• Have lower life expectancy
• Struggle to maintain stable housing
• Are overrepresented in homelessness statistics, and
• Are overrepresented in interactions with the justice system.

Some of the common functional impairments

generated by people with psychosocial

disability include:

• Inability to complete self-care tasks on a daily or weekly basis

• Reduced or substantially reduced executive function; inability to plan, organise, manage tasks and regulate emotions

• Reduction in communication ability, expression, engagement and understanding

• Strong social avoidance, reduction in community access and participation, isolation.

These examples all apply directly to the six specific life skill areas the NDIA uses to assess reduced

or substantially reduced functional capacity: communicating, socialising, learning, mobility, self-care and self-management.

Psychosocial disability, like mental illness, is still often misunderstood and stigma remains. For example, it is not uncommon to hear that people with psychosocial disability “only need prompting” to undertake activities of daily living, suggesting that it is not necessary or a “real” disability support. This is discriminatory and fails to recognise that the functional impairment for someone with psychosocial disability is analogous to the inability to complete a task for other (physical) reasons.

However, psychosocial disability does differ from other disabilities in some ways:?

• It cant always be seen.

• Although psychosocial disability itself is enduring, support needs can be variable and episodic; sometimes there is a need for intensive support and sometimes minimal or no support.

• The relationship between medical diagnosis, impairments experienced, and level or type of disability varies from person to person, including because of the other supports around them (physical and social) and their individual experience of having a mental health condition.

• The experience of a mental health condition and its treatment can also cause long lasting impairment, as some symptoms remain even after clinical treatment, and because of the side effects of medication or trauma associated with restrictive or ill-informed practices. This means that functional (in)capacity can be ‘cumulative and variable, even when symptoms of the condition have responded to treatment, or ‘do not appear to be ongoing or permanent.’°

3The need to define psychosocial disability in these terms, and compare it to other disabilities, is unfortunate and underlines the issue with NDIS eligibility assessment as it currently operates. NDIS access and assessment seem to have strayed from a model grounded in relative judgement

of functional capacity—personalised yet socially grounded, about disability—to judgement of diagnosis—connected to a medical understanding of disability and without personal or social context. For a more in-depth description of psychosocial disability and its relation to medical or social models of disability, see the glossary of National Mental Health Consumer & Carer Forum (2011). Unravelling Psychosocial Disability: A Position Statement by the National Mental Health Consumer & Carer Forum on Psychosocial Disability Associated with Mental Health Conditions.

Tune. (2019). Review of the National Disability Insurance Scheme Act 2013, p.74.

Access Denied: Psychosocial Disability and the NDIS

Key data about mental health prevalence

WITHIN AUSTRALIA’S ADULT POPULATION (PEOPLE AGED 16-85)

8.5M (3

can expect to experience a mental disorder over their lifetime“.

ape ape ape aD ape ape ape aD abe abe abe abe

are likely to are likely to experience ‘severe, experience a severe persistent and complex’ mental illness“, psychiatric needs.

These are individuals who:

• havea severe and enduring mental illness (usually psychosis)

• have significant impairments in social, personal and occupational functioning that require intensive, ongoing support

• require extensive health and community supports to maintain their lives outside of institutional care.“.

’Australian Institute of Health and Welfare (AIHW). (2025). Targeted analysis. ’Based on an adult population (15 - 64 years) of 17,701,331 people (Australian Bureau of Statistics. (2025). National, state and territory population. ®Productivity Commission. (2011). Disability Care and Support, Report no. 54, Volume 2, p.754.

16 Australian Psychosocial Alliance

Key data about people with psychosocial disability in the NDIS

PEOPLE WITH A PRIMARY PSYCHOSOCIAL DISABILITY IN THE NDIS (JUNE 2025)

• 72% live in major cities
• 2% live in remote or very remote areas

oe

comprise

• 8.8% 99%

over 18 years of age of all participants

e a

• 9% 13%

a

• 30% engaged socially and with their community (5,764) Culturally and re) First Nations Linguistically 1 1 To . are employed (of those aged 15+))

Overall How NDIS satisfaction plans are managed Reported level of function @ 7% (4,247) high function (the lowest 53 % @ 3% of payments are self-managed service and support requirements) pesticipants with a —lower than every other disability group ©) 61% (39,882) medium function psychosocial disability “) 86% are plan managed-higher than 31% (20,180) low function (the highest COMPARED TO every other disability group service and support requirements) 66% 11% are NDIA managed of all participants

5. ‘It’s taken a sharp turn’: psychosocial disability access

to the NDIS

FINDING 1

Psychosocial disability access to the NDIS has reduced dramatically over recent years. This reduction is far larger than for any other disability type.

FINDING 2

There have been no formal changes in NDIS eligibility criteria or legislation that can explain reduced NDIS access for people with psychosocial disability.

For people with a psychosocial disability, gaining access to the NDIS had always been ‘complicated and difficult.’ They’ve got their own language’. From late 2023, it has become increasingly clear that something has changed.

Prior to this, following assessment of someone’s capacity and support needs, if the independent expert judgement suggested NDIS support was appropriate and necessary, access was generally achievable. Over the years, support workers gained expertise and knowledge to assist people to determine if they were likely to be eligible THEY’VE GOT THEIR and identify what evidence and information would OWN LANGUAGE. support a successful application.

From late 2023, staff across APA organisations reported increased delays in the application process. NDIS data from this time (Quarter 2 (Q2) 2023-24) subsequently confirmed this anecdotal concern. Reassurance from the NDIA at this time acknowledged a new computer system and revised processes. However, the decline in the number of people receiving access and the access rates for people with a primary psychosocial disability has not reverted since.

“Staff participant in APA engagement sessions regarding NDIS access, July 2025.

18 Australian Psychosocial Alliance

Almost two years on, APA staff tell us that people being denied access to the NDIS are the least well they’ve worked with, physically and psychosociauy. NDIS applicants and APA staff have told us that they are required to provide more evidence than they used to, at great effort and (inequitable) cost. APA organisations believe the quality of applications is higher than in previous years. Yet the rate of successful access continues to decline. The process is increasingly disheartening:

‘It’s getting to the point now, it doesn’t really matter what kind of case you can make’

IT DOESN’T REALLY MATTER WHAT KIND OF CASE YOU MAKE.

FIGURE 1

National NDIS access rate for psychosocial disability (PD) and all disabilities, with total PD access decisions, 2020-2025

5.1 Analysis of NDIS access data

NDIS data is released quarterly. The NDIS releases summary quarterly reports to ministers,’° and supplementary statistical information available for the whole Scheme or by state, territory or service district.” The APA analysis relies on data in these supplementary reports, particularly data on assessment of access per quarter by primary disability group. Our analysis focused on the national access trend.

Figure 1 shows that for people with a psychosocial disability, both the total number of NDIS access decisions made (green bar) and the number of people granted access (blue bar) are on a downwards trend. It also shows a growing gap between the access rate for people with a psychosocial disability (lime line) and all disability types (dark purple line), between Q1 2020/21 and Q4 2024/25.

The divergence between psychosocial disability access, and the unchanged rate of overall access, is stark. Even more so, since all disabilities includes psychosociauy disability—meaning the reduced psychosocial disability access rate is bringing down the overall rate of access across the Scheme.

5000 90% 4500 80% 4000 3500 3000 2500 2000 1500 1000 500 i LS i tT [ [ [ g R 2 8 © * I Full rollout July 2020 Act amendments March 2022 70% 60% 50% 40% 30% 20% 10% O% Q4 ai Q2z Q3 Q4 Qi Q3 Q4 ai Q3 Q4 T T Administrative changes i Act amendments October 2024 ®Staff participant in APA engagement sessions regarding NDIS access, July 2025. NDIA. (2025). Quarterly Reports. NDIA. (2025). Quarterly report supplements. ’ The trend holds for the five mainland states, however it is not as obvious in Tasmania or the Territories, due to smaller quarterly numbers (thus greater variance, or sometimes also below the NDIS threshold of 11 for reporting exact access numbers).

Access Denied: Psychosocial Disability and the NDIS

NDIS Participants With Psychosocial Disability

Figure 2 shows that people with psychosocial disability are reducing as a percentage of NDIS participants overall. The Productivity Commission estimated in 2017 that people with a primary psychosocial disability would comprise 13.9% of all participants.”? At present this number is just 8.8%

FIGURE 2

NDIS participants with psychosocial disability as a percentage of all NDIS participants, 2022-2025

——

10.5%

95% 9.0% wee 85% 8.0% un Sep Dec Mar Jun Sep Dec Mar Jun Sep Dec Mar Jun 2022 2023 2024 2025

Another way of understanding this decline in participation in the Scheme is to consider the total decisions made for people with a psychosocial disability as a proportion of all access decisions.

Figure 3 shows that at 3% in the last quarter (green line), this number is well below the predicted participation rate of 13.9% (pink line) and the peak of under 16% shortly after full scheme roll out. Even if all people seeking access were granted access (blue line), the access rate would still be lower than the estimated rate, suggesting that there are real barriers to even applying for access.

FIGURE 3 “= Access decisions made

Total decisions made and access granted for people with a primary psychosocial —®— Access granted disability as a proportion of all decisions for all disabilities, 2019-2025 “=== Expected access granted for psychosocial disability

18% 16% — be NON 4% |— ye SE nn

m [4 PN SS

10% 8% IWZAN

6% NN 4% Poo, oJ

2% 0% a | a a2 @ a] a az a3 a4{a «a2 a3 a}]|a az a a4] a az a a 19-20 ‘20-21 2-2 ‘2-23 23-24 ‘24-25

“Productivity Commission. (2017). National Disability Insurance Scheme (NDIS) Costs, p.241.

20 Australian Psychosocial Alliance

Figure 4

Figure 4 presents change in access rates relative to Q1 2020/2021, which coincides with full Scheme roll out. The relative rate of access for those that do not have a primary psychosocial disability has remained the same, while for people with a primary psychosocial disability it has decreased substantially.

FIGURE 4

Relative access rate for psychosocial disability and ——®— Access rate relative to June 2020 (PD) on-psychosocial disability NDIS participants, 2020-2025 — <i - Access rate relative to June 2020 (all disabilities excl PD) 120% a–s- oc) Sp ae- t-te = <<. a ——g ——m | -— - =m - - ~~) ee 80% t— 60% aw A KN _N 40% 20% 0% a a2 a a|a «az a3 {a = az a a] a a2 a3 |] a az a3 a 2020-2021 2021-2022 2022-2023 2023-2024 2024-2025 Finally, Figure 5 shows access rate variation for every disability type within the Other physical: 41% NDIS. While there are several disability types that have experienced a reduction in A er paysicas* 7 K0, mies. . “ + Acquired brain injury: 25% access between full Scheme roll out in mid-2020 and mid-2025, the difference Spi wean rene _ . + Spinal cord injury: 20% for psychosocial disability is 62%. This is far larger than the next largest reduction. . Intellectual disability: 15% The next largest reductions in access rate by disability type are:

FIGURE 5

NDIS access rate variation by disability type, Q1 2020/21 to Q4 2024/25

Taken cumulatively, these five figures demonstrate that changes to NDIS access are disproportionately impacting people with psychosocial disability.

Access Denied: Psychosocial Disability and the NDIS

5.2 Analysis of APA organisational data on discharge to the NDIS

After confirmation of the downward trend in access in the official NDIS data, the APA decided to investigate internally. APA organisations sought to test whether this declining rate of access was due to something happening at the NDIA, within APA organisations, or in the profile of the people seeking NDIS access.

Early data from APA services (from mid-2024) showed that the average time between submitting an application to receiving an outcome went from an average of 17 to 25 weeks, and there was a drop off in the number of exits to the NDIS. From a service perspective, staff reported that the people they were assisting to apply for NDIS support had the same or similar profiles and needs to those they had assisted previously, and that there had been no change in the quality of applications.

The APA then asked our services to provide longer-term data for comparative analysis. Data was provided from four organisations providing the following four programs, across 13 sites (some organisations provided more than one program):

• Commonwealth Psychosocial Support Program (CPSP): up to 12 months individual recovery support for people with moderate to severe mental illness. Provided nationally.
• Victorian Early Intervention and Psychosocial Recovery Program (EIPSR): 12-months of individual recovery support for people following an inpatient or outpatient episode of care.
• NSW Housing and Accommodation Support Initiative/ Community Living Support: a long-term program providing individual recovery support.
• Victorian NDIS access program: a service designed specifically to assist people to access the NDIS. Referrals are accepted from anywhere, but the team assess suitability for the NDIS before providing support.

Figure 6 provides both the real numbers of people exiting the program (blue bar) and those exits that were made to the NDIS (pink bar). The green line represents the trend in the proportion of exits to the NDIS.

CASE STUDY

As a carer for her son with schizophrenia, all Diana wanted was someone to assist her and her family with regular support. A daily check-in to ensure her son

was looking after himself and to ease the isolation they both so often felt. Assistance to find suitable employment, including upskilling support for her son who desperately wanted to work, would have also been helpful.

She hoped the NDIS would provide this support, that was otherwise not available through the mental health system. Psychiatrists and other professionals said her son was a good candidate and the support the NDIA could provide would open up possibilities for him.

Diana applied four times to the NDIA, on behalf of her son, and was met with four rejections, and over the years of trying she watched her son’s mental health decline.

On the fifth time, they were successful. She doesnt believe she did anything different this time, and wonders what changed to suddenly grant them access.

Diana is thankful for the support theyre now receiving, but issues with the type of support they receive remain an ongoing challenge. A lack of skilled psychosocial workers in their regional town means that that theyre not receiving support from someone who understands what her son needs and can assist him before he needs clinical support.

For Diana and her son, it doesn’t have to be

complicated. But the right support when he needs it could make all the difference.

*Name and identifying details have been changed to protect anonymity.

Access Denied: Psychosocial Disability and the NDIS

It feels like system-enforced

speed humps’: why is psychosocial disability

access to the NDS dropping so quickly?

FINDING 3

NDIS eligibility assessments continue to demonstrate poor understanding of mental health and psychosocial disability, and ignore expert assessments.

FINDING 4

NDIS eligibility assessment responses are inconsistent, non-individualised and lacking in natural justice.

Non-expert assessorshave, on multiple occasions, identified inappropriate treatments not being triedit as grounds to reject permanency.

FINDING 5

NDIS eligibility assessment processestreate disproportionate barriers for people from marginalised backgrounds, including people with psychosocial disability.

24 Australian Psychosocial Alliance

Annual Report No.1 of the 48th Parliament

Submission 22

The NDIS response to the downwards access trend for people with psychosocial disability emphasises changes to a range of policies, procedures, guidelines, business systems, and training and development, all with the aim of ensuring ‘that eligibility assessments are applied consistently and transparently across all disability groups.’²⁰

Similarly, in a 2022 report on NDIS access barriers for people living with psychosocial disability, a team from the University of Sydney’s Centre for Disability Research and Policy found that:

• ‘The application process does not accommodate for mental illness and psychosocial disability.’
• ‘[the] Process excludes people because of symptoms of mental illness and psychosocial disability’
• ‘[the] Process excludes people with prior negative experiences and trauma histories’
• ‘Staff are unqualified and do not understand psychosocial disability – particularly its episodic nature’.²²

The current NDIS access statistics show the situation today is even worse for people with psychosocial disability than back in 2018 or 2022.²³

in this section, we present three explanations for the disproportionate impact on people with a psychosocial disability: Assessments and staff demonstrate poor understanding of psychosocial disability. Assessments ignore expert assessments provided as evidence There are significant barriers to application and access.

even before these recent changes, NDIS eligibility assessment process had demonstrated an inability to meet the needs of people with psychosocial disability. In a 2018 report by the Sydney Policy Lab at the university of sydney, the expert project team documented that ndis eligibility assessment for people with psychosocial disability was plagued by the following issues:

• ‘Many people with severe, persistent and disabling mental illness are assessed as ineligible…’
• ’Eligibility assessments demonstrate poor understanding of psychosocial disability…’
• ’Eligibility assessment was inconsistent across different sites … ’
• ‘There was poor understanding of co-morbidity.’²¹

²⁰NDIA correspondence with APA member organisation, 2025. ²¹Smith-Merry et al. (2018). Mind the Gap: The National Disability Insurance Scheme and psychosocial disability. Final Report: Stakeholder identified gaps and solutions, p.21–22. ²²Hancock et al. (2022). Examination of NDIS Access Barriers For People Living With Psychosocial Disability: final report, P.44–46. ²³Amendments were made to the ndis act in 2022 with the intention of improving the experience for people with a psychosocial disability. These amendments included a shift from psychiatric to psychosocial to remove the ‘medicalised terminology focus’, and to recognise that psychosocial disability may be broader than the classification of Psychiatric condition. The eligibility reference (24(1a)) Was changed From “one or more impairments attributed To A Psychiatric conditions” to

Page 34

6.1 NDIS rejections: poor understanding of psychosocial disability and ignoring expert assessments

The NDIS legislation mandates that the NDIA must consider a prospective participant’s age and residence status, and whether they meet the disability or early intervention requirements within the NDIS Act (section 24 and section 25 of the Act respectively).

Assessors determine whether ‘the person has one or more impairments to which a psychosocial disability is attributable,’* and whether ‘the impairment or impairments are, or are likely to be, permanent.’? #6

The NDIS application process also demands detailed and specific evidence, often from a range of different medical and allied health professionals.

The APA agrees that there should be strong legislative and agency guidelines for how NDIS eligibility is assessed. But assessing impairment and permanence also requires a high level of psychosocial disability literacy. It is not a tick box exercise.

People with psychosocial disability have shown us letters of rejection and relayed conversations they have had with the NDIA that demonstrate a poor understanding of mental health conditions, and of the functional impairments that can arise from them. We see examples of an inability to distinguish mental health conditions from impairment and from psychosocial disability. These include:

• An emphasis on psychiatric diagnosis, while evidence of impairment is overlooked. We have heard of unreasonable, and sometimes irrelevant, requests for evidence of diagnosis, for example:

  • Asking for medical records which are beyond timeframes that records must be held, from practitioners that the person has not had contact with for many years.

• Not accepting statements from psychiatric registrars because they have not known the person long enough (noting that in the public mental health system, no registrar will ever have a long-term relationship with a patient yet are often relied on for such assessments). This point underlines the disconnect between the NDIS and the public health system—a smoother interface between the two would produce better outcomes in both systems.

Rejection of permanence on the basis of a supposed lack of exploration of treatments for the condition, without consideration of how this may or may not impact the impairment adversely, or whether such treatments are available, appropriate or necessary.

A standard form of this rejection states:

‘Even when your condition or diagnosis is permanent, we’ll check if your impairment or impairments are permanent too. For example, you may not be eligible if your impairment is temporary, still being treated, or if there are remaining treatment options.’

The available evidence confirms that you have schizophrenia.

However, this evidence does not indicate that all available and appropriate treatment options that are likely to remedy your impairments have been explored. These treatment options must be explored before this requirement can be met?

As part of the Administrative Appeals Tribunal (AAT) judgement NDIA V Davis [2022] FCA 1002 (Davis), the judge clarified that ‘permanent impairment in s24(1) means an impairment which is of an enduring nature. The question for the decision maker is whether the impairment(s) experienced by an individual (rather than the cause of the impairments or the specific diagnoses made about a medical condition) has or have an enduring quality so as to require supports funded and/or provided under the NDIS Act on an ongoing basis.’

NDIS rejection letter, 2025. De-identified and shared with consent.

Access Denied: Psychosocial Disability and the NDIS

NO DOCTOR’S\nSAID I’M CURED.

We spoke with people who had received multiple\nNDIS rejections—even six times—and been told\nhis impairments were not permanent. Some\n had lived with a condition for multiple decades.

In some cases, treating clinicians have explicitly\nstated in evidence provided to the NDIA that there\nis no appropriate treatment options available in\nthi case. And yet, the same response has come\nback: not permanent, all treatment options not\nextlored. Unfortunately, this NDIA response shows\na misunderstanding of the fact that treatments may\bbe designed for mental health symptoms, rather than psychosocial disability impairments. It also\nsuggests that the NDIA is not taking into account a\npint explicitly made in a 2018 review of the Act:\nthat a disability can be present even where active\ntreatment or intervention may not be required.”®

For NDIS applicants with multiple and complex\nneeds, there is a mixture of pain and confusion\nabout the NDIA response. One expressed\nexaspiration as how to respond to the rejection on\npermanence, when ‘no doctor’s said I’m cured, or \nwill be cured’? It is hard to understand the meaning\nof permanent in such cases, and the inconsistent\nthreshold for judging it. In the words of one staff\nmember, ‘Theyte very lovely, theyre very respectful, but they don’t understand the foundation of mental\nhealth or disability:3°

The APA holds multiple concerns about the NDIS\nasessment process and the practices around it.

First, having observed this process hundreds of\ntimes, our staff state that the manner of rejection\nhhas become increasingly generic, even seemingly\nautomatic. One staff member shared that it ’seems\nlke this is a copy and paste response, the wording\nis the same-*! This is at odds with the individualised\nnature of the Scheme. The practice has increased\nin frequency for the psychosocial disability cohort, delaying applications and denying access without\ndue consideration of individual circumstances and\nevidence provided. The APA is concerned that\ncurrent NDIA practice displays a tendency o repeatedly misunderstand the interplay between mental health conditions and psychosocial disability, resulting in increasingly automatic rejection.

[THEY GIVE] COPY AND PASTE RESPONSES.

8Tune. (2019). Review of the National Disability Insurance Scheme Act 2013, p.74.

22APA consumer during NDIS engagement session, 2025.

3°Staff participant in APA engagement sessions regarding NDIS access, September 2025. 3’Staff participant in APA engagement sessions regarding NDIS access, July 2025.

Issues With NDIA Eligibility Assessments

Second, when pushed to expand on which treatments have not been evidenced in application materials, NDIA responses are often vague, almost evasive. Subsequent requests for more information are inconsistent and arbitrary. There is a deep procedural injustice in applicants being asked to provide extremely detailed personal evidence, and a large government agency not being held to the same standard of detail in return. People often experience a strong disconnect between the time they have been in treatment and the range of treatments tried, and the brief official NDIA response.

Third, when NDIA responses are clear (or are clarified through an appeal process), we have evidence of them identifying treatments that are inappropriate, or which only a clinician in consultation with their client could determine would be appropriate. In many cases, these examples point to misunderstanding of the relationship between symptoms, impairments and treatments. In some specific and concerning cases, NDIA responses

as to the treatments that have not been explored

have included identification of specific drugs, and also electroconvulsive therapy (ECT, or shock therapy). Notwithstanding ongoing debate over this treatment’s efficacy and harm, that it would be identified as an option by a non-clinician NDIS assessor is deeply inappropriate.

This practice is also inconsistent with the NDIAss official guideline, which states: ‘The NDIA does not make recommendations for specific treatments/interventions. The treating clinician will decide on appropriate treatment and/or interventions for a person:3?

Fourth, the NDIS guidelines for Applying to the NDIS state ‘you may not be eligible if… there are known, available and appropriate evidence-based clinical, medical or other remaining treatments options that are likely to remedy the impairment:*? Our observation of current NDIA practice is that eligibility assessment of people with psychosocial disability emphasises known

32NDIA (2024). Accessing the NDIS: a guide for mental health professionals, p.8.

33NDIA (2024). Our Guidelines: Applying to the NDIS, p.7.

treatments over appropriate ones. There is also little consideration of whether treatments are available— whether regionally, or on cost (equity) grounds* (for more on this see section 6.2 Barriers to application and access).

Fifth, and finally, responses from the NDIA frequently ignore the many expert assessments provided during the eligibility assessment process. The suggestion that not all treatment options have been explored often explicitly contradicts direct advice from psychiatrists and other expert practitioners about (in)appropriate treatments in individual cases.

Perhaps most worrying is the lack of respect for expert professional advice that is demonstrated by the NDIA current rejection of detailed evidence. As one of our staff members said, ‘It feels as if theyre invalidating the assessment of all of these professionals who have supported [consumer’s name] for longer than they [the NDIS] have!® NDIS applications demand substantial time from clinical and other practitioners. While one application used to take around 20 hours,”¢ with multiple attempts now commonly required, it is now taking upwards of 100 hours per applicant.*”

This commitment of many hours of professional time is occurring at the same time as there are workforce shortages for clinical professionals across the country in mental health and psychosocial disability settings. To spend so much time supporting in-depth applications, and have these expert opinions ignored, indicates

a troubling process at present that requires serious attention and revision. Unfortunately, with examples such as this, there is a level of care and effort and expense demanded of applicants and clinicians that is not reciprocated by the NDIA.

The AAT decision NDIA V Davis [2022] FCA 1002 (Davis) clarifies that “available” should be understood as meaning available to a particular individual, including whether can, in reality, access which includes financial as well as practical considerations (such as living in a remote area). 35Staff participant in APA engagement sessions regarding NDIS access, September 2025.

36Tune. (2019). Review of the National Disability Insurance Scheme Act 2013, p.87.

37Clinical staff member at partner organisation, 2025.

Australian Psychosocial Alliance

6.2 Barriers to application and access

Meeting the considerable evidence requirements IDENTIFICATION (ID) REQUIREMENTS of the NDS eligibility assessment process is challenging for all applicants. NDIA requirements duplicate existing proof of

ID processes already established through other government agencies such as Centrelink. This creates

a barrier for those who may have difficulty obtaining

The eligibility assessment process creates the following range of barriers to NDS access for

people with a psychosocial disability. These fall most heavily on those least able to meet them. These barriers include:

COST

• upto $1,750 to obtain clinician reports.

• onecase of $800-$1,200 for someone to obtain their own medical records from a long-term general practitioner (GP).

PREFERENCE FOR PSYCHIATRIST OR

CLINICAL PSYCHOLOGIST REPORTS

• Such a preference produces a hierarchy of evidence, prioritising a medical view to determine diagnosis and impairment, and sidelining other independent expert assessments of disability, such as those from occupational therapists or mental health support workers who have a long-term relationship with the applicant.

• This creates another cost barrier as such practitioners are very expensive.

• Such clinical practitioners are also highly inaccessible: wait times of six months or more, especially for regional and rural people.

• Ignoring reports from mental health support workers who have a long had a long-term relationship with the applicant, or from family who may have been providing significant care and support to date. such documentation, including:

People from First Nations or Culturally and Linguistically Diverse backgrounds.

People who do not have contact with their family of origin, and

People who are homeless.

ADMINISTRATIVE PROCESSES

These demand a certain level of education, cognitive functioning or in/formal support, such that they directly discriminate against certain disability or marginalised cohorts and people without informal supports.

NEW MEETING REQUIREMENTS

Community Connections meetings and other informal connection points can be problematic for some people with psychosocial disability, given impairments such as communication difficulties, social isolation, distrust of authority and institutions, anxiety, and symptoms such as anosognosia (where a participant doesnt represent their true needs, downplaying impairment). These meetings are occurring regardless of need, value or the risks of negative impact.

Insufficient information is provided

to participants about the purpose and potential outcomes of these meetings.

6.2 BARRIERS TO APPLICATION AND ACCESS CONTINUED…

PROLONGED PROCESS

• It often takes more than 12 months from the time a person decides to make an application and start the evidence collecting process, to achieving an outcome. For some people, the trauma and stress associated with the process means they drop out.

DIFFICULTIES IN PARTAKING

IN AN APPLICATION PROCESS WITHOUT A FIXED ADDRESS.

• This is deeply problematic for the many people in this cohort who are homeless or experiencing other forms of housing insecurity.

| CAN’T IMAGINE HOW THE SYSTEM WOULD BE FOR SOMEONE TO NAVIGATE

WITHOUT SUPPORT.

38APA consumer during NDIS engagement session, 2025. Australian Psychosocial Alliance

Taken cumulatively, these barriers are formidable. People with greater financial resources, education, time and stronger networks are more able to navigate such challenges (even after accounting for their disability). Although there are some cases where connection with a public hospital or mental health service will provide access to clinicians and other support in preparing an application, this is time-limited and often crisis-driven.

A particularly troubling point is that the stories we have heard come from people who are already connected to supports. They are using our services and expertise to help them make an application, after we have considered that NDIS support is necessary and appropriate in their case. Yet these applications are being rejected at a record rate.

In the words of an APA service user who has had their NDIS application rejected three times: ‘I cant imagine how the system would be for someone to navigate, without support, without psychiatrist and doctor support.’

6.3 Concern for people with multiple and complex needs

The APA is concerned that people with multiple

and complex needs, with co-occurring trauma and marginalisation, and from intersectional backgrounds are increasingly experiencing rejection of their applications, or not engaging in the process altogether.

There is a perverse outcome from the refinement

and tightening of NDS processes that asks people

to prove each of their conditions and impairments individually. For people with complex needs, the cumulative impact of multiple challenges produces an impairment outcome that is greater than the sum of its parts, so to speak. Our staff relay how in previous years, hey could talk about people with multiple and complex needs in combination within an application. The eligibility assessment process would look at the person holistically (ie. all Functional impairment).

This is no longer the case. Instead, applicants now need to meet the criteria related to one condition. This is much harder for clients with multiple and complex needs or multiple conditions. Often, no one condition is the sole cause of complexity and impairment. The result is that, individually, the impairments are rejectable and NDIS support is denied, regardless of whether a holistic assessment of functional capacity would render an entirely different outcome.

Furthermore, the APA understand that the Complex Support Needs Pathway, a critical support route that was designed to offer specialised support to complex and marginalised participants, has been shifted to internal NDIA referral only. This pathway had previously been marketed by the government as a means to improve outcomes for this cohort.*? Removal of external access and referral effectively closes this pathway, except at the discretion of internal NDIS planners and subject to cost pressures. To our knowledge, removal of external access to the pathway was not made public. There are state and territory government-funded access pathways that prioritise people with multiple and complex needs, operating within hospitals and within community, but we understand that even these programs are experiencing increased challenges in achieving NDS access for NDLS applicants. This includes major increases in application preparation times and waits, with an overall reduction in successful discharge to NDIS.

This has a profound impact at a human and a service level. Staff spoke about the departure from an earlier implicit policy of no wrong door. Instead, people with multiple and complex needs risk receiving a simple no and falling out of the system altogether. This problem clearly underlines how the NDIS assessment process for people with psychosocial disability focuses too much on diagnosis and treatment rather than functional capacity.

?9NDIA. (2018, November 16). Improved NDIS planning for people with complex support needs

Zahra, a young woman living with

OCD and anxiety, yearns for secure employment but has faced barriers in getting the support she needs to do this and to live life independently.

Fighting bureaucracy and a complicated process, Zahra applied to the NDIS, but was rejected.

The NDIA reasoned that she had not tried all possible treatments, including a form of exposure therapy that is not currently appropriate for Zahra.

Zahra is lucky, she’s receiving supports through a state-funded psychosocial program while she goes through the arduous task of re-submitting another NDIS application. But the program shes on wasn’t designed for this—it was designed as a 12-month program to develop individual recovery goals.

Australian Psychosocial Alliance

Zahra described the NDIS as ‘the only oasis in the desert!

The NDIAss focus on permanency and exhausting all possible treatment options means that currently it’s an oasis out of reach, leaving her to navigate the desert as best she can.

Zahra wants to see an NDIS that supports individualised healing and recovery, promotes productivity and prevents decline.

With the support of APA organisations, Zahra will apply again. She hopes that this time, the NDIS oasis can prove more than a mirage.

“Name and identifying details have been changed to protect anonymity.

‘Do | even try again? What do gain from trying to get into this system?’

The impact of reduced

pyschosociai disabiity acess to

the NDIS

There is a substantiat risk to peopie witb pyschossociab disabitity becaase tbey are beiing exctuded froa tbe NDTS at a timo wben tbere ore alnost no otber suppoits avaiiable outsidt te NDI5.

Tbere is an iapropriote and incarurate view that there ate too many pepsone wiib psycbosociai diisabilty in tie NDIS.

Most recommeodations tor impprovements to the NDIS for pesons witb psyckosociai disability reman unimpiemented over a decade since the Scheme began.

Challenges with NDIS access for people with psychosocial disability have serious negative impacts on service users and families, carers and supporters.

People With Psychosocial Disability Are Being Left Behind

People with psychosocial disability are being left behind. Unable to access the NDIS or suitable alternative support options, their lives are significantly impacted. This can lead to preventable decline, and greater loss of function and capacity. Often, it ends in eventual NDIS access after avoidable damage is done. This comes at greater cost to the NDIS and to governments. It’s a false economy with a human price. Importantly, regardless of cost pressures on the Scheme, this is not what the NDIS set out to do. People with disability are not getting access to a universal national program.

The process of rejection compounds peoples challenges. We heard people describe receiving their eligibility decision as dehumanising and demoralising. People with long-term mental health conditions and disabilities related to them make themselves vulnerable during the application process in the hope of support and a change in their life circumstances—only to be told that they are not eligible. They feel unworthy.

Since the earliest days of the NDIS, there have been calls for a psychosocial disability specific approach (see section 7.2). The difficulties in reconciling a recovery approach that underpins mental health and psychosocial support, with the focus on impairment and permanency, has also been well documented.*° Despite the NDIS committing to a recovery framework—which has not been effectively translated into practice—-there has been insufficient interest in creating an NDIS that meets the needs of this cohort.

When it [the NDIS] works well, it’s brilliant, and it does a great role for our guys and it keeps them out of the longer-term institutions. But in the instances where we have these sorts of situations, it’s hard to remember those good cases and it’s hard to pick what’s working well with the NDIS. It just feels like everything’s falling apart around you.

It’s hard to not be frustrated and really hurt by the systemic issues we face with the NDIS in this space.

Manager of a regional APA service providing medium-term clinical care and rehabilitation services. In some cases, service users have been unable to be discharged for years, because of NDIS access and planning delays.

4°0’Halloran, P. (2015). About Psychosocial Disability and the NDIS: An Introduction to the Concept of Holistic Psychosocial Support.

Australian Psychosocial Alliance

7.1 Risk to the cohort:

A significant number of participants with psychosocial disabilities; conditions the scheme was not intended to fund when it was set up.’⁴⁵

The APA knows from engagement for this report, and our day-to-day work in communities across the country, that the issue of NDIS access is affecting people deeply. This impact is felt particularly keenly in regional and rural communities, where there are already fewer services.

Although there are geographic differences, there is a real risk from multiple policy directions. In addition to our first key finding, that psychosocial disability access to the NDIS has reduced dramatically over recent years, there is documented significant unmet need for psychosocial support outside of the NDIS.⁴¹

Although unmet need has been on the agenda for health and mental health ministers during 2025, as yet there is no firm commitment to addressing it. There is also a parallel commitment to new psychosocial disability non-NDIS supports. In August 2025, the Minister for Health, Disability and Ageing, the Hon Mark Butler MP commented that psychosocial disability is the next disability type in line for development of Foundational Supports, following the announcement of Thriving Kids for developmental delay and autism. The Government estimates this will take at least 18 months to put in place. The government and NDIA must avoid a situation where the gap widens further for people with psychosocial disability and the larger group of Australians with severe and moderate unmet need for psychosocial support.

Many community mental health programs were defunded to fund the NDIS. Unfortunately, the breadth of support these former programs provided has not been matched by the NDIS, given the higher threshold for access and the individualised nature of NDIS support.

Against this historical backdrop, the APA is particularly concerned about commentary in support of psychosocial disability being moved out of the NDIS altogether.44 A view that in order to ‘cut the scheme’s growth rate… the second phase of Health Minister Mark Butler’s [Foundational Supports] proposal… must tackle the significant number of participants with psychosocial disabilities; conditions the scheme was not intended to fund when it was set up.’⁴⁵

The Productivity Commission modelling from 2011 included psychosocial disability, forty-six two years before the NDIS commenced. Psychosocial disability may well have been a later addition to the initial design of the NDis, after physical and intellectual disability, but it has been in the Scheme from the beginning.

Importantly, this debate must not conflate mental health conditions with psychosocial disability. People with psychosocial disability are a subset of people with severe mental health conditions. They live with a real disability.

The 2011 Productivity Commission report identifies that:

‘Many people with significant and enduring psychiatric disabilities have the same day-to-day or weekly support needs as people with an intellectual disability or acquired brain injury. These can include assistance with planning, decision making, scheduling, personal hygiene and some communication tasks. Regular support and, in some cases, supported accommodation, allows such people to live successfully in the community.’48 A thorough understanding of psychosocial disability is essential for informed policy debate in the current context of NDIS reform. There is no scenario in which hundreds of thousands of people with unmet mental health needs should have those needs met within the NDIS. As such, a view that there are too many people with psychosocial disability in the NDIS is stigmatising and discriminatory.

Page 44

Unlike many other disability types in the Scheme that have greatly exceeded estimates, psychosocial disability numbers have remained below earlier calculations: for example the 64,000 estimate for 2019/20, or 13.9% of the Scheme at this time, as

given by the NDIA and confirmed by the Productivity Commission.? The current number of 65,272 in Q@4 2024-25 accounts for only 8.8% of participants.°

Updating the original Productivity Commission estimates, from the 2011 Disability Care and Support inquiry.*! Using 2025 population data and the same methodology, there should be 70,805 people with a primary psychosocial disability in the Scheme.

The APA is not arguing that this many people with psychosocial disability must promptly be added to the Scheme. Rather, we are concerned about ensuring that NDIS accessibility operates on an equitable footing, with clear relative assessment of capacity and impairment, regardless of disability type. Political judgements about NDIS reform, responding to unmet need, and the place of people with psychosocial disability within these policy changes, should start from understanding of the facts.

The biggest risk to people with psychosocial disability at present is that their access might continue to decrease, rather than increase. While these debates about policy reform are certainly live, there is no firm action either on development of Foundational Supports for psychosocial disability or on addressing unmet psychosocial support need. Meanwhile, reassessments for eligibility have commenced, including for those people rolled into the NDIS with a different type of assessment, from earlier support systems—thus more exposed to reassessment. There seems to be no plan to support vulnerable people through this process.

There are 5,500 fewer people receiving NDIS support for psychosocial

disability than expected.

Policy goals such as reducing the overall cost of the Scheme should not undermine the right of people with psychosocial disability to access the NDIS in a fair and transparent way.

IT WAS HEARTBREAKING TO OPEN UP ABOUT MY WORST DAYS TO MY SISTER AND DOCTOR WHO HELPED ME FILL IN THE FORMS. | FELT EXTREMELY VULNERABLE AND DYSFUNCTIONAL. | FELL DEEPER INTO DEPRESSIVE EPISODE WHEN THE NDIS SAID NO.

Unsuccessful NDIS applicant

*9NDIA. (2016). Annual Report 2015-16, p.26; Productivity Commission. (2017). National Disability Insurance Scheme (NDIS) Costs, p.241 Productivity Commission. (2020). Mental Health, Report no.95, vol. 3, p.851 SONDIA. (2025). Participant Data ‘Productivity Commission. (2011). Disability Care and Support, Report no.54, vol.2, p.754. ‘Australian Bureau of Statistics. (2025). National, state and territory population ‘3The Productivity Commission methodology for ‘identifying people likely to require individualised supports within the NDIS assumes the following: ‘0.4 per cent of the adult population (or 12 per cent of those adults with severe mental disorders) would have “severe, persistent and complex” psychiatric needs; The adult population is taken to be 15-64 years. An updated version of this modelling for current Australian population data, identifies 17,701,331 people aged 15 - 64 years; of which 0.4% is 70,805. Productivity Commission. (2011). Disability Care and Support, vol.2, p.754ff

Australian Psychosocial Alliance

Access Denied: Psychosocial Disability and the NDIS

The conversations we had in developing this report are not new and reflect the failure to implement changes outlined in multiple government-commissioned and independent reviews and reports over the previous decade or more. Some, including the landmark NDS Review released in 2023, await a formal government response.

In addition to formal government and independent reports, there have been years of advice and information from peak bodies, service providers and people with lived experience and their carers, families and kin about how the Scheme can and should be responding differently to people with significant and enduring psychosocial disability. This advice is all targeted towards ensuring the NDIS can deliver the benefits envisioned by the Productivity Commission back in 2011.

Meanwhile, changes to the NDIS have continued at a rapid pace. These changes have not, to date, delivered what governments and people with psychosocial disability require.

Access Denied seeks to draw attention to the troubling downwards trend in psychosocial disability access to the NDIS. But it also seeks to point the way forward in terms of reform for this group. Figure 7 highlights the recommendations and possibilities for reform not taken*. The sector stands ready to contribute to reform, savings and better outcomes. To do so we must begin on implementing a stronger psychosocial disability specific approach within the NDIS.

This is just a selection of the many reports and recommendations made since the earliest days of the NDIS implementation, including from the trial sites.

**Access Denied: Psychosocial Disability and the NDIS 37

FIGURE 7

Timeline of landmark reports and inquiries on psychosocial disability and the NDIS, 2011 to 2025.

Consistent unheeded calls for action

The well-established need for a bespoke psychosocial disability approach

A SELECTED HISTORY OF REVIEWS & REPORTS

Productivity Commission Disability Care and Support: Productivity Commission Inquiry Report 2011

• Supports outside of NDIS
• Specialist workforce

JULY NDIS Launch Launch of the National Disability Insurance Scheme (NDIS) 2013

Mental Health Australia Report Psychosocial Supports Design Project - Final Report APRIL

• Outreach 2016 2017 Joint Standing Committee Inquiry
• Specialist workforce
• Assistance with evidence gathering

August The provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition 2017 • Supports outside of NDIS

• Fit for purpose assessment tool
• Monitor access rates

Productivity Commission • Outreach OCTOBER • Carer engagement National Disability Insurance Scheme • Specialist workforce (NDIS) costs - Study report • Psychosocial pathway 2017

• Specialist workforce
• Outreach

University of Sydney Report Mind the Gap: The NDIS and Psychosocial Disability – Final Report JANUARY 2018 • Supports outside of NDIS

• Specialist workforce
• Outreach

David Tune AO PSM Review Review of the NDIS Act 2013 DECEMBER

• Remove medical terminology 2019
• Prioritise functional capacity
• Outreach

NDIS Review Panel Working Together to Deliver the NDIS – Final Report OCTOBER • Psychosocial pathway 2023 • Specialist supports outside of the NDIS

• Practice standards

Australian Psychosocial Alliance • Improve access & interface with mental health systems Access Denied: Psychosocial disability OCTOBER and the NDIS

• Improve access 2025 • Psychosocial pathway, including home
• Informed reform throughout
• Uplift NDIA capability & workforce

7.3 Marginalization and

the ripple effect

As part of our engagement while developing Access Denied, the APA heard how NDIS access challenges leave people to fall through the gaps. These challenges are even greater for people experiencing a range of other, co-occurring factors of marginalisation. Partner organisations in adjacent sectors attested to this fact during engagement sessions. We spoke with organizations delivering homelessness, alcohol and other drugs (AOD) and mainstream health services. All of these organisations described the deepening difficulties of their service delivery to people from marginalised backgrounds, as NDIS access has decreased for people with multiple and complex needs.

The data on these compounding challenges is clear.

The original 2011 Productivity Commission report into the NDIS identified that around 35% of people with a primary psychosocial disability who were likely to be eligible for NDIS support and with the highest needs were described as likely to have experienced long periods of hospitalisation or require hospitalization. They were also likely to be at risk of homelessness if not receiving support, and having limited familial and social networks.

The most recent data from the Specialist Homelessness Services data set (for 2023/24) identifies redacted people who accessed a specialist homelessness support service, who also had a diagnosed mental health condition and a disability such that they required assistance in one or more core activity areas. redacted were homeless at the time of requesting assistance, while the remainder were at risk of homelessness. Overall, while these numbers have gone up and down year to year, over the last ten years (redacted-), the number of people with a diagnosed mental health condition and a disability has increased by 41%.

• 38% of people with a psychosocial disability receive the Disability Support Pension^[57], and psychological or psychiatric conditions are the most commonly recorded primary medical conditions for people aged 16–64 years receiving the Disability Support Pension.^[58]
• Amongst those on the NDIS with a primary psychosocial disability, only 11% are employed, with a high likelihood that the other 89% are receiving income support.^[59]
• The Household, Income and Labour Dynamics in Australia (HILDA) Survey shows that in 2023, people with a long-term mental health condition reported the highest level of financial stress, with almost one in three (32.2%) in financial stress. This proportion is significantly higher than people with other long-term health conditions (excluding mental health) (14.5%) and people with no long-term health conditions (10.2%).^[60]

Contrary to some long-held prejudiced ideas, there is ample evidence that shows that people with mental illness and psychosocial disability are far more likely to be the victim of violent crime rather than the perpetrator.^[61] The vulnerability of people with mental illness who are homeless also increases the risk of being victims of crime.^[62]

Finally, families and caregivers of people with mental health issues are also significantly impacted. Around 40% of mental health caregivers already provide 40 or more hours of unpaid care per week, and mental health families and caregivers have lower than average wellbeing, face disproportionate health impacts and experience high levels of psychological distress.^[63]

These statistics underline how, over time, the cumulative impact of mental health challenges, disability, loss of support networks and increasing poverty, all expose people to greater risk and vulnerability. They are also a consequence of and contribute to psychosocial disability. Unfortunately, they also make it harder to achieve NDIS access.

References:

• Productivity Commission. (2011). Disability Care and Support, vol.2, p.761.
• AIHW. (2024) Specialist Homelessness Services Collection data cubes redacted- . https://www.aihw.gov.au/reports-data/specialist-homelessness-services/ *AIHW. (2024) People with disability in Australia 2024, catalogue number DIS 72, p.372 https:// www.aihw.gov.au/publications/comprehensive-assessments/people-with-disability-in-australia-2024
• NDIA. (2025). Quarterly dataset for psychosocial disability, June 2025, Table 22.
• National Mental Health Commission. (2025). National Report Card 2024, p.29.
• Watson et al. (2001), Stuart.(2003); Thornicroft(2020)
• Nilsson et al. (2020). *Mental Health Carers Australia. (2025). Submission to the Productivity Commission National Mental Health and Suicide Prevention Agreement Review.

People with psychosocial disability are having

their Access Denied right now by the NDIS eligibility assessment process.

APA analysis of psychosocial disability access to the NDIS demonstrates a concerning downwards trend. There is evidence of discrimination against people with psychosocial disability as a cohort. This conclusion

is clear, regardless of whether this is occurring as an inadvertent consequence of internal NDIA policy and process changes.

When we speak with people with psychosocial disability who are seeking NDIS support, we hear stories about rejection, delay and decreasing hope of getting much- necessary support. Our data analysis confirms these stories as accurate. Not only is there just one lifeboat in the ocean-your chances of getting in are worse than they’ve ever been.

8.1 Reduced psychosocial disability access to the NDIS

The NDIA has stated that there have been no formal changes to eligibility criteria or legislation that directly arget people with psychosocial disability. The APA welcomes this confirmation. However, what the Agency has changed is its own guidance, processes and systems. These were intended to be universal and disability impartial. This has not proven so. Psychosocial disability access has dropped more than any other disability type. Efforts to achieve greater “scheme integrity”—to improve outcomes and to lower costs—are producing inequitable disability-specific results.

The APA is concerned that behind the numbers there are real Australians with psychosocial disability seeking support, directly impacted by NDIA decision-making that is inexpert, inconsistent and lacks natural justice.

Attention now needs to be paid to the manner in which internal refinements and improvements are producing this inequitable access outcome.

Federal, state and territory governments have acknowledged the decrease in psychosocial disability NDIS access. However, the APA is concerned that this fact remains one data point among many in a protracted policy reform process, coupled to stalled budget negotiations.

Australian Psychosocial Alliance

8.2 A false economy with a human price

In addition to significant individual barriers, people with psychosocial disability face an intimidating political environment: A quick stocktake shows how strongly the deck is stacked against people with psychosocial disability:

• NDIS access has reduced for people with psychosocial disability
• There are fewer mental health programs in community than before the NDIS
• Policy solutions are years away, whether Foundational Supports, the new National Mental Health and Suicide Prevention Agreement, a response to unmet need or otherwise
• There is misinformed commentary about people with a psychosocial disability not fitting into the NDIS
• Governments and the media are focused on NDIS cost savings
• There seems to be little political will to address the specific needs of people with psychosocial disability.

There are budgetary pressures on the NDIS and federal, state and territory governments. But Australians who need, and are eligible for, NDIS support have a right to NDIS support. Federal-state/territory negotiations are stalled. The imperative for budget savings seems to be masking poor practice and poor outcomes that are disproportionately impacting people with psychosocial disability.

The APA understands the challenges of federal-state/-territory negotiations over health and disability funding. However, without attention and resolution, this issue will produce risks at multiple levels of government.

The consequence of people not getting access is that mental health and wellbeing declines, and sometimes the only option is for people to access services which are not fit-for-purpose or as effective. Often these are high-cost state-/territory-funded services. Waiting lists for already-stretched mental health services will increase. People who need the NDIS will miss out on necessary and impactful supports. This is a false economy with a human price.

Annual Report No.1 of the 48th Parliament

Submission 22

Perhaps the most unfortunate element of the situation described in Access Denied is the avoidable nature of this problem. The timeline of unimplemented official and independent advice presented in Figure 7 underlines this fact. Governments may be stalled in their negotiations as they debate the extent of future liabilities that will sit on their side of the ledger. What they must no longer shy away from is the availability of suggestions to treat the problem differently. The greatest cost will come from continued inaction and lack of support, not provision of support.

The biggest risk to governments, whether federally or at state and territory level, will be of terrible adverse and unavoidable human, system and community consequences. Governments must act in the immediate term, as well as proceeding with medium- and long-term reform. This will ensure there is appropriate NDIS access and support now, as well as sufficient alternative services available to people in future. Now is the time to change course, before it is too late. Otherwise, we will continue to witness a widening gap for people with psychosocial disability and the broader group of people with unmet psychosocial support needs, no matter which service system they look to.

Our key findings and recommendations set out a means to remedy access issues with the NDIS for people with psychosocial disability. Change is necessary and long overdue.

Unfortunately, access is not the only concern the APA holds about the NDIS and how it serves people with psychosocial disability. There are other issues of planning, utilisation, experience and NDIA practice that threaten positive outcomes for people with psychosocial disability. Attention to access, and the NDIA’s understanding of and ability to work with people with psychosocial disability, should be a first step towards broader improvement and reform.

In addressing the issues raised in this report, the federal government and NDIA should pay attention to several related issues shared as advocacy priorities by some disability sector peak bodies, including the need for:

• greater market stewardship from the NDIA

• pricing reform, centring complexity and quality independent pricing
• registration, with risk-proportionate variation.

The ongoing task of NDIS reform should provide an opportunity to ensure people get the support they need and were promised, while the country gets the sustainable NDIS it requires. At present, people within psychoscial disability are losing out from invisible tweaks to NDIS processes that disproportionately affect them. It is time for change, time for equity, and time for people with psychosocial disability to experience NDIS access differently.

8.3 Charting a path forward

for psychosocial disability

The APA hopes that Access Denied: Psychosocial Disability and the NDIS goes some way toward increasing the visibility of this inequitable situation. We have sought to highlight:

• Dramatically reduced recent psychosocial disability access to the NDIS
• Why psychosocial disability access to the NDIS has fallen
• The human and service impact of this fall in psychosocial disability NDIS access.

People with psychosocial disability are having their Access Denied unfairly.

It is time for that to change.

See for example: National Disability Services (2024). State of the Disability Sector Report 2024; Ability Roundtable (2025) Disability Service Provider Financial Benchmarking Insights.

References

Ability Roundtable., (2025). Disability Service Provider Health Policy Analysis, endorsed by the Psychosocial Financial Benchmarking Insights, DSC Annual NDS Project Group. (2024). Analysis of unmet need for Conference 2025, psychosocial supports outside of the National Disability Insurance Scheme: Final report. https://www.health.gov. au/sites/default/files/2024-08/analysis-of-unmet- to-dsc-conference-2025-sector-sustainability. pdf.

Australian Bureau of Statistics. (2025). National, state and territory population, https://www.abs.gov.au/statistics/ Mental Health Australia. (2025). Renewed Statement people/population/national-state-and-territory- on Addressing Unmet Need for Psychosocial Support population/latest-release. Outside the NDIS, https://www.mhaustralia.org/articles/ Australian Institute of Health and Welfare (AIHW). statements/renewed-statement-addressing-unmet- (2024). Specialist Homelessness Services Collection data need-psychosocial-support-outside-ndis/. cubes 2011–12 to 2023–24, [https://www.aihw.gov.au/(https://www.aihw.gov.au/reports/homelessness-services/shsc-data-cubes/)reports/homelessness-services/shsc-data-cubes/contents/data-cubes.

Mental Health Carers Australia. (2025). Submission to the Productivity Commission National Mental Health and Suicide Prevention Agreement Review, [https://www.(https://www.mentalhealthcarersaustralia.org.au/Web/Contents/FilteredContent_Submissions/2025-National-Mental-Health-and-Suicide-Prevention-Agreement-Review.aspx)](https://www.mentalhealthcarersaustralia.org.au/Web/Contents/Filtere dContent_Submissions/2025-National-Mental-Health-and-Suicide-Prevention-Agreement-Review.aspx).

National Disability Insurance Agency (NDIA). (2016). Annual Report 2015-16. ttps://www.ndis.gov.au/publications/annual-report/annual-report-2015-16.

— (2018, November 16). Improved NDIS planning for people with complex support needs, https://www.ndis. gov.au/news/1002-improved-ndis-planning-people-complex-support-needs.

— (2024). Accessing the NDIS: a guide for mental health professionals, https://www.ndis.gov.au/how-ndis-works/psychosocial-disability/information-health-professionals-service-providers-and-supporters.

Butler, M. (2025, August 20). Speech from Minister Butler, National Press Club – 20 August 2025. [https://www.health.gov.au/ministers/the-hon-mark-butler-mp/media/speech-from-minister-butler-national-pressclub-20-august-2025](https://www.health.gov.au/ministers/the-hon-mark-butler-mp/media/speech-from-minister-butler-national-press club-20-august-2025).

Hancock, N, Gye, B, Digolis, C, Smith-Merry, J, Borilovic, J & De Vries, J. (2019). Commonwealth Mental Health Programs Monitoring Project: Tracking transitions of people Community Mental Health Australia and the University of Sydney. [https://www.sydney.edu.au/content/dam/corporate/documents/faculty-of-medicine-and-health/research/centres-institutes-groups/cmha-usyd-ndis-transitions-final-report-september-2019.pdf](https://www.sydney.edu.au/content/dam/corporate/do cuments/faculty-of-medicine-and-health/research/centres-institutes-groups/cmha-usyd-ndis-transitions-final-repor t-september-2019.pdf) Hancock, N, Scanlan, JN, Mellifont, D & Hamilton, D. (2022). Examination of NDIS Access barriers for people living with psychosocial disability: Final report. The uploads/2022/04/National-Survey_Barriers-to-NDIS- pdf.(https://mhcc.org.au/wp-content/uploads/2022/04/National-Survey_Barriers-to-NDIS-access_-Report.pdf)](https://mhcc.org.au/wp-conte nt/uploads/2022/04/National-Survey_Barriers-to-NDIS-acces s_-Report.pdf).

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he Australian Psychosocial Alliance

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Australian

Psychosocial Alliance

Australia’s leading providers of psychosocial support services

connect@psychosocialalliance.org.au

www.psychosocialalliance.org.au