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Submission to the Joint Committee on Public Accounts and
Administration
Inquiry to the Administration of the NDIS
Prepared by Every Australian Counts
January 2026
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Introduction:
Every Australian Counts (EAC) thanks the Joint Committee on Public Accounts and Audit (the Committee) for the opportunity to make this submission.
Every Australian Counts is a grassroots campaign made up of people with disability, their families and carers, and the people who work alongside them. Our mission is to make sure the NDIS works for the people it was designed to support. We work to amplify the voices of people with disability and to ensure their experiences shape policy and implementation.
This submission provides a summary of the work undertaken by EAC between October 2024 to Jan 2026, covering a critical period following the passage of the NDIS Amendment Act 2024. It draws on our ongoing, close engagement with the disability community during this time. Our submission draws attention to administrative processes and their consequences and outcomes, intended and unintended, for NDIS participants. The issues raised go to the heart of the Committee’s Terms of Reference, particularly in relation to:
- The effectiveness and appropriateness of NDIS administration and governance;
- The management of risk, and participant safety;
- The impacts of administrative decisions on participant outcomes and scheme sustainability.
The views presented here reflect the concerns, insights, and priorities shared with us directly by people with disability, their families, carers, and advocates. As always, our goal is to ensure the perspectives of those most affected by NDIS policy are front and centre in decision-making.
Administrative Failure as a Source of Harm
Across EAC’s engagement with the disability community, a consistent message has emerged: administrative processes within the NDIS are increasingly creating harm, rather than mitigating it. Participants and families report that poorly designed, rushed, or inconsistently implemented administrative changes have led to loss of essential supports, service interruptions, heightened distress, and serious risks to health and safety.
For participants, the NDIS provides essential support. It funds supports that enable basic daily living, communication, mobility, community participation, all of which are protective from neglect or abuse. When administrative systems fail, through delays, rigid rules, inadequate communication, or lack of individualised consideration, the consequences can be immediate and severe.
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Findings from EAC Community Engagement
- Poor Communication and Navigability Following Legislative Change
Following the passage of the NDIS Amendment Act 2024, EAC surveyed more than 450 members of the disability community to assess awareness and early impacts. Only one in four respondents felt they understood the changes, while more than one in five reported little or no understanding at all1.
This lack of clarity is not a minor administrative issue. Participants reported being unable to determine what evidence was required, how decisions were being made, or how to maintain existing supports. Confusion and inconsistent advice from the NDIA created delays and errors that directly affected continuity of care and safety.
More than 60 per cent of respondents reported negative experiences following the changes, with many losing supports or facing barriers to accessing replacements. These outcomes point to systemic administrative weaknesses in information provision, staff training, and risk assessment.
- Eligibility Reassessments and Risk to Participant Safety
EAC and 254 other disability organisations jointly raised concerns in early 2025 about the pace and design of eligibility reassessments and structural reforms2. Community feedback indicates that approximately 1,200 participants per week are being reassessed, often with minimal notice and limited opportunity to provide additional evidence.
Participants described reassessment processes as confusing, opaque, and procedurally unfair. In many cases, people were removed from the Scheme with little explanation, despite ongoing and significant support needs. The administrative framing of these decisions failed to adequately consider risk of harm, continuity of care, or the broader system impacts when individuals are abruptly exited from the NDIS.
Such practices raise serious questions about whether current administrative settings adequately protect participant safety, uphold human rights obligations, or represent sound risk management.
- Support Needs Assessments and Budget-Setting Tools
EAC’s election-period survey in March 2025 found that nearly half of respondents were deeply concerned about the fairness and safety of proposed new Support Needs Assessments. Participants feared that standardised tools, delivered by underqualified assessors, if not carefully designed and administered, would fail to capture individual circumstances and create inappropriate funding outcomes. These concerns were strongly reiterated in the EAC December focused on Support needs Assessments.
1 Community Feedback on NDIS Legislation Changes - Every Australian Counts 2 Media Release: Take the Time for Codesign: 255 Organisations Demand More Time to Codesign NDIS Reforms - 3
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Community members raised serious concerns that the proposed Support Needs Assessments (including the I-CAN tool) and associated budget-setting mechanisms represent a fundamental shift away from individualised decision-making towards administrative categorisation and cost control. Participants described the assessment as functioning less as a needs assessment and more as a classification tool designed to place people into predetermined funding “bands”, with limited transparency about how outcomes are generated or how budgets are set. Concerns were raised that assessments would rely on outdated or incomplete data, algorithmic decision-making, and internal NDIA systems known to contain errors, increasing the risk of inappropriate funding outcomes and loss of essential supports.
From an administrative perspective, community members highlighted significant weaknesses in governance, risk management and accountability. There was strong concern that embedding assessment tools and budget mechanisms in legislation would effectively insulate funding decisions from meaningful external review, creating a closed loop where internal reassessments repeat the same tool rather than reconsider individual evidence. Participants and legal advocates warned that this approach substantially limits the ability of the Administrative Review Tribunal to scrutinise the substance of decisions, undermining procedural fairness and increasing the risk of systemic error. The lack of clear rules about what evidence can be considered, if and how participant-provided professional reports are considered, and how discretion is exercised was seen as a major administrative gap.
Community members also warned that the proposed model risks privileging administrative consistency and expenditure restraint over participant safety and outcomes. Concerns were raised that standardised assessments conducted by NDIA staff without appropriate clinical qualifications, limited time, or established relationships with participants are unlikely to capture complex, psychosocial, or contextual support needs. Participants emphasised that removing nuance, goals, and life circumstances from budget-setting decisions increases the likelihood of underfunding, service disruption, and harm, particularly for people with complex needs, regional participants, and those reliant on individualised, non-standard supports. These concerns point to a need for stronger safeguards, clearer accountability, and robust risk-of-harm assessments within NDIS administrative processes.
From an administrative perspective, the risk is clear: systems designed for efficiency rather than individualisation increase the likelihood of underfunding, unmet need, and downstream harm, including hospitalisation, carer burnout, and safeguarding failures.
Section 45 of the NDIS Act – creating delayed payments and service disruption
Section 45 of the NDIS Act, together with the associated Plan Administration Rules, gives the NDIA broad discretion over the timing, manner and conditions of payments, but in practice this discretion is being exercised through opaque administrative systems that create avoidable risk and harm. Community experience shows that claims can be rejected by the NDIS portal with no explanation, no indication of what rule has been breached, and no guidance on how to rectify the issue. This lack of transparency creates significant administrative failure: participants and self-managers are held to complex compliance requirements, yet are not given the information necessary to correct errors or challenge incorrect decisions. The consequences can be significant, rejected claims without reasons lead directly to delayed payments, cashflow stress, unpaid workers, interruption of essential supports, and participants being forced to front costs they cannot afford while attempting to resolve an “invisible” problem. At minimum, effective administration under Section 45 requires that payment rejections clearly state the reason, identify corrective steps, and provide an accessible review pathway. A payment system that withholds payment without explanation undermines accountability, procedural fairness, and the safe administration of the Scheme.
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Funding Periods and Administrative Risk
In May 2025, the introduction of shorter funding periods represented a significant administrative change with limited consultation or risk mitigation. EAC coordinated a joint statement from disability organisations warning that quarterly and monthly funding releases do not align with how supports are actually delivered3.
Participants reported increased risk of service interruptions, inability to secure providers, and heightened administrative burden — particularly for self-managers and those with complex or fluctuating needs. From a public administration perspective, these changes shift risk onto participants while increasing system complexity and transaction costs.
Maintaining 12-month funding as the default is not only a matter of choice and control; it is a risk management measure that supports continuity, workforce stability, and participant safety.
Support Lists and Loss of Essential Supports
EAC’s mid-2025 survey on the introduction of NDIS Support Lists revealed widespread harm linked to rigid administrative categorisation of supports. More than half of respondents reported losing access to previously funded supports that were essential to their safety and daily functioning4.
Participants described being left without assistive technology, home modifications, or automation tools that supported independent living and medical safety. In several cases, respondents explicitly stated that removal of these supports placed their lives at risk.
Administrative processes to seek alternatives were often slow, inconsistent, and inaccessible. Requirements such as additional letters, reassessments, or manual approvals introduced delays that left people without support for weeks or months. These findings indicate a failure to adequately assess and manage risk prior to implementation.
Individualised Supports as a Protective Mechanism
The NDIS was designed on the principle that individualised supports reduce risk, prevent harm, and enable people with disability to live safely and well. EAC’s work consistently shows that when supports are tailored, flexible, and stable, participants experience better outcomes and reduced reliance on crisis systems.
Conversely, administrative decisions that prioritise standardisation, cost containment, or speed over individual circumstances increase risk across the system. These risks are not hypothetical — they manifest in emergency hospital admissions, mental health crises, family breakdown, and preventable harm.
Effective scheme administration must therefore recognise individualised funding and decision-making not as a cost pressure, but as a core mechanism for safety, sustainability, and value for money.
3 Joint Statement on New NDIS Funding Periods – from Every Australian Counts and Disability Rights Organisations - 4 Every Australian Counts Survey Results Highlight Impact of NDIS Support Lists - Every Australian Counts 5
6 Recommendations
Every Australian Counts recommends that the Committee consider the following in its inquiry:
1. Embed risk-of-harm assessments into all major administrative changes, with explicit
consideration of participant safety and continuity of supports.
2. Strengthen transparency and communication, ensuring participants receive clear, accessible,
and consistent information about administrative decisions.
3. Ensure individualised decision-making remains central, particularly in assessments, support
lists, and funding structures.
4. Maintain 12-month funding as the default, with shorter periods only where genuinely appropriate
and chosen by participants.
5. Require genuine co-design5 and piloting of administrative reforms before full implementation.
6. Improve internal governance and accountability mechanisms to identify and address
administrative failures that cause harm.
Conclusion
The evidence gathered by Every Australian Counts demonstrates that administrative design and implementation within the NDIS can either protect or endanger the lives of people with disability. When administration fails to account for individual needs, risk, and lived experience, the consequences are profound.
This inquiry presents an important opportunity to refocus the administration of the NDIS on its foundational purpose: supporting people with disability to live safe, dignified, and fulfilling lives through individualised supports that work in practice, not just in policy.
Every Australian Counts thanks the Committee for considering this submission and for its attention to the administrative integrity and human impact of the NDIS.
5 Media Release: Take the Time for Codesign: 255 Organisations Demand More Time to Codesign NDIS Reforms - 6