NDIA Accountability Project

Addressing the needs of all NDIS participants from diverse backgrounds

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Inquiry Into The National Disability Insurance Scheme

Amendment (Getting the NDI$ Back on Track No. 1) Bill 2024

SUBMISSION TO THE SENATE STANDING COMMITTEE ON COMMUNITY AFFAIRS LEGISLATION COMMITTEE

Address:

  • Street Address: 132 Main Street
  • Suburb and Postcode: Osborne Park, 6008
  • Contact Information:

Date of Submission: JULY 2024

Organisation Details:

  • President: Angelo Cianciosi
  • Chief Executive Officer: Wendy Rose
  • Author: Siyat Abbi PhD

Table of Contents

About KIN Disability Advocacy (formerly EDAC) ………………………………………………………………………………….. 3

Introduction Analysis of the Bill …………………………………………………………………………………………………………. 4

Detailed Provisions and Implications ..................................................................................................... 4

KIN Advocacy Comments on Bill Amendments ……………………………………………………………………………………. 5

Evaluation of Human Rights Considerations .......................................................................................... 5

Areas where the Bill might vary or raise concerns in relation to international conventions: .............. 6

Issues to be revisited for further amendments ………………………………………………………………………………….. 7

The Definition of "NDIS Supports" .......................................................................................................... 8

Transitional Provisions and APTOS ........................................................................................................ 8

Needs Assessments ................................................................................................................................. 8

Defining a participant's right to a replacement assessment ................................................................. 9

Alternative Arguments ……………………………………………………………………………………………………………………. 10

Financial Sustainability without Restricting Growth ........................................................................... 10

Inclusive and Adaptive Eligibility Criteria ............................................................................................. 10

Enhanced Flexibility in Fund Utilization ............................................................................................... 10

Balanced Fraud Prevention Measures .................................................................................................. 10

Genuine and Transparent Co-Design .................................................................................................... 11

How the Bill Deals with Diversity …………………………………………………………………………………………………….. 11

Eligibility Criteria and Access to Supports ............................................................................................ 11

Flexible Use of Funds ............................................................................................................................. 12

Quality and Safeguarding Amendments ............................................................................................... 12

Co-Design and Participation ................................................................................................................. 12

Alternative Approaches to Strengthen Diversity Considerations ……………………………………………………… 13

Culturally Competent Assessments and Supports ............................................................................... 13

Inclusive Policy Development ............................................................................................................... 13

Targeted Outreach and Support ........................................................................................................... 13

Monitoring and Accountability .............................................................................................................. 14

Conclusion ………………………………………………………………………………………………………………………………………. 14

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About Kin Disability Advocacy

formerly EDAC:

Kin Disability Advocacy formerly (EDAC) is Western Australia’s peak not-for-profit organisation advocating for the rights of people with a disability, from a Culturally and Linguistically Diverse (CALD) background and their family and carers.

Membership Information:

  • Kin Disability Advocacy is a member of the National Ethnic Disability Alliance (NEDA).

Funding Sources:

  • Recurrent funding: Australian Department of Social Services (DSS)
  • WA Department of Communities Disability Services (DS)
Service Delivery Areas:
  • Metropolitan areas
  • Regional areas
  • Remote areas in WA
Additional Projects & Initiatives:
  • State-wide CALD advocacy services
  • Individual generalist advocacy to WA’s North-West region (Kimberley and Pilbara)
  • Human rights-based self-advocacy training for individuals with disabilities and families/carers
  • Digital Communication Project funded by the DSS addressing intersectionality between disability and ethnicity across various aspects such as services, policies, legislation etc.
  • Cultural competency training provided within the disability sector adhering strictly to National Disability Services Standards

####### Gratitude Statement:

We express our gratitude towards being given an opportunity to provide comments regarding THE “National Disability Insurance Scheme Amendment (Getting The NDIS Back On Track No. 1) Bill 2024.

######## Appreciation Note:

Our appreciation extends also toward the SENATE STANDING COMMITTEE ON COMMUNITY AFFAIRS Legislation Committee who undertook this inquiry thereby affording us another chance at expressing views concerning said bill.

Introduction

Analysis of the Bill

The National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill 2024 aims to address financial sustainability, combat fraud, and simplify eligibility in the NDIS. It introduces new definitions for disability supports, a revised assessment process, and quality and safeguarding amendments. The Bill responds to concerns raised in the Independent Review of the NDIS and is part of efforts to ensure the Scheme’s long-term viability and effectiveness by implementing a set of legal modifications to improve the long-term financial viability, combat fraudulent activities, and simplify the requirements for eligibility in the NDIS. The Bill introduces significant amendments to the National Disability Insurance Scheme Act 2013 (NDIS Act), focusing on defining disability supports, revising the assessment process for NDIS entry, and managing participant transitions between plans as outlined below:

Definitions of Disability Supports: The Bill introduces new definitions for disability supports to offer clarity regarding the kind of services that can be legitimately financed under the NDIS. The objective is to limit the range of assistance, guaranteeing that only essential and rational forms of support are encompassed (Bills Digest, 2024, p. 4).

New Assessment Process: A new evaluation procedure will be implemented to qualify for admission into the NDIS, consisting of two distinct eligibility categories:

Early intervention and disability requirements. This method, which consists of two pathways, is intended to meet the demands of individuals with different requirements and guarantee that resources are allocated appropriately (Bills Digest, 2024, p. 4).

Transitioning Plans: The Bill details the method by which current NDIS participants will move from their previous plans to new ones, ensuring that support remains consistent while adhering to the updated definitions and assessment procedures (Bills Digest, 2024, p. 4).

Quality and Safeguarding Amendments: The amendments to the quality and safeguarding provisions involve the authorisation of quality auditors and the extension of infringement notice powers to officers at Executive Level 2.

The objective of this is to improve the supervision and regulatory structure of the NDIS (Bills Digest, 2024, p. 4).

Expectations and Support

The Bill aims to align expectations and ensure that the necessary support is provided according to their specific need (Bills Digest, 2024, p. 9).

  • Ending Participation: The Bill grants the NDIA CEO with enhanced authority to terminate the status of a participant if they no longer satisfy the eligibility criteria. This guarantees that resources are allocated to individuals who require them the most and contributes to the preservation of the Scheme’s soundness (Bills Digest, 2024, p. 10).

Areas where the Bill might vary or raise concerns in relation to international conventions:

Financial Sustainability Measures and Funding Growth Cap

International Standard: The CRPD emphasises that States Parties should ensure the availability and sustainability of resources to uphold the rights of persons with disabilities (Article 4.1).

However, we note that the Bill introduces measures to cap the growth of NDIS funding to 8% by July 2026 (Bills Digest, 2024, p. 5). By this measure, we can comfortably say that this cap could potentially limit the resources available for necessary supports, thereby affecting the sustainability and adequacy of services provided to persons with disabilities. This could be arguably viewed as inconsistent with the CRPD’s requirement for sustained investment in disability supports.

Eligibility Criteria and Access to Supports

International Standard: The CRPD mandates that persons with disabilities should have access to the services they need without undue administrative barriers (Article 9, Article 19).

Potential Variance: The Bill aims to streamline eligibility criteria but also introduces stricter definitions and processes for accessing the NDIS (Bills Digest, 2024, p. 4). The concern is that these tighter criteria might exclude some individuals who need support, particularly those in the early intervention stream who may not transition to permanent disability support. This could restrict access to necessary services, contravening the CRPD’s call for broad and inclusive access to support.

Flexibility in the Use of Funds

International Standard: The CRPD advocates for the autonomy and independence of persons with disabilities, including the freedom to make their own choices (Article 3, Article 19).

Potential Variance: While the Bill introduces more flexible funding arrangements, the shift from “reasonable and necessary supports” to “reasonable and necessary budgets” might limit the specific services that participants can access based on their individual needs (Bills Digest, 2024, p. 5). There is a risk that this could reduce participants’ control over their support plans, impacting their autonomy and ability to tailor support to their unique circumstances.

Fraud and Overcharging Measures

International Standard: The CRPD requires that States Parties protect persons with disabilities from exploitation, violence, and abuse (Article 16).

Potential Variance

The Bill includes measures to address fraud and overcharging by providers, which are necessary to protect the integrity of the NDIS (Bills Digest, 2024, p. 6). However, overly stringent measures or frequent assessments might place additional burdens on CaLD participants, potentially creating an environment of mistrust and reducing the perceived fairness and accessibility of the system.

Co-Design and Participation

International Standard: The CRPD emphasises the importance of involving persons with disabilities in the design and implementation of policies and programs affecting them (Article 4.3).

Potential Variance: our previous submission echoed for genuine co-design in the legislative process If the implementation of the Bill’s provisions does not adequately involve persons with disabilities and their representative organisations, it may fall short of the CRPD’s standards for inclusive and participatory policy development.

Observation: co-design is not required: The Bill now requires the Minister to consider co-design principles, but it doesn’t make this a legal requirement.

Issues to be revisited for further amendments.

  • Does not take a Whole of Person Approach: The Bill may not fully account for people with multiple and interrelated disabilities, which could lead to inadequate support.

  • Unclear review and appeal rights: The Bill lacks a clear way to appeal or replace individual’s needs assessment.

  • Broad powers to require assessments: The Bill provides the NDIA with broad powers to require medical assessments, which could be difficult to obtain especially by our cohort clients from CaLD backgrounds.

  • Limits on Support and Spending: The Bill gives the NDIA a lot of power to control how participants use their funding, reducing participant choice and control.

  • Punitive measures: The Bill gives the NDIA new powers to change how participants’ plans are managed and raise debts if they decide funding has been misused.

  • Limits on Support and Spending: The Bill gives the NDIA a lot of power to control how participants use their funding, reducing participant choice and control.

The Bill gives the NDIS Minister powers to make Rules and determinations (legislative instruments’) relating to the NDIS. The Government says it is committed to genuine consultation and co-design with the disability community to make those legislative instruments, but that commitment is not contained in the Bill. For many in the disability community, locking in that commitment is a priority issue.

Amendments to Subsection 4(9A) of the NDS Act

For example, the amendments require the Minister to have regard to the principle of co-design in subsection 4(9A) of the NDIS Act when making legislative instruments establishing:

  • how needs assessments will be conducted; and
  • the method to be used in calculating a participant’s budget.

These amendments do not legally require the Minister to co-design these instruments — they would only require the Minister to have regard to the value of co-design.

Thus, it is our contention that this is not helpful by obviously stating just statements of principle, but significantly unable to address concerns that the disability community could be excluded from development of these legislative instruments.

The disability community require the Government to maintain commitment to co-design agenda and build the confidence and trust.

The definition of “NDIS Supports”

In our previous submission, we raised concern about the wording and structure of proposed section 10, which defined NDIS supports.

We noted that selectively including only elements of the United Nations Convention on the Rights of Persons with Disabilities (‘CRPD’) and leaving out other parts of the CRPD was problematic.

We are satisfied that the new amendments recognised these concerns and amended the Bill to the effect that the amended section 10 ‘NDIS supports’ will be defined entirely by NDIS Rules to be made after the Bill passes and this will be through engaging with the disability community to develop the Rules defining NDIS support’.

Transitional provisions and APTOS

Kin also noted the major problems using the Applied Principles and Tables of Support (‘APTOS’) as a transitional measure can create for our major cohort population.

We are contented that this has been amended and APTOS as a transitional measure has been removed However, the Bill would require the Minister to make a transitional rule to define “NDIS supports” until a permanent NDIS Rule can be developed for this purpose.

Needs Assessments

The initial Bill proposed that the needs assessment and budget-setting method would be limited to considering needs that stem from impairments that meet the disability or early intervention requirements for entry to the Scheme.

Our cohort clients would have experienced double disadvantage, and this approach would have significantly imposed artificial distinctions in the way a person with multiple and interrelated

disabilities accesses supports and could result in them receiving inadequate funding for supports,

disregarding their CaLD backgrounds and other limitations associated with it.

To this effect, we concur to the amendments that needs assessments and budget calculations consider a participant’s support needs:

  •    arising from an impairment that meets the disability or early intervention requirements;

and

  •  where that impairment is impacted by another impairment that does not meet the

disability or early intervention requirements.

Determination of whether a support is ‘reasonable and necessary’ as per old framework plans.

Subsequently, Kin consider these amendments would bring the Bill more into line with the intentions of the Scheme, recommendations made by the NDIS Review and the Joint Standing Committee on the NDIS, as well as decisions of the MT regarding the need to take a whole of person approach to funding. Practicable and sensible approach to this amendment bill is to ensure participants are told which of their impairments the NDIA believes meet the disability or early intervention requirements.

Right to receive needs assessment report

In our previous submission, we raised concerns that the Bill did not give participants the right to view and comment on their needs assessment report before it is finalised.

We are now satisfied that participants will have the say and an ‘opportunity to review the report and provide input and feedback before the CEO makes any planning decisions’ and clarifies that ‘a participant’s plan [is] to be prepared with the participant’.

The Supplementary Explanatory Memorandum explains “it is necessary for the participant to receive the report after the CEO, as the CEO cannot provide it until it has been received from the assessor, and this now settles our concern regarding the right to receive Need Assessment Report.

Defining a participant’s right to a replacement needs assessment. If a participant is unhappy with conclusions in their initial needs assessment report, the participant should be given another opportunity to request a replacement needs assessment, and the agency order the participant secure a replacement needs assessment report in collaboration with the skills and expertise of the health professional who originally prepared. Thus, Kin maintain that a participant’s right to at least one replacement assessment should be legislated in the Bill.

Constraints on obtaining supports, spending funds and plan management.

Kin is concerned about the introduction of new powers allowing the NDIA to impose conditions on how a participant obtains supports, restrict spending of flexible funding, or override a participant’s plan management request.

These powers are too broad, and amendments need to provide more guidance and safeguards on their use.

Alternative Argument

A Balanced Approach to Ensuring Financial Sustainability and Comprehensive Support

Financial Sustainability without Restricting Growth

Proposal: Instead of imposing a rigid cap on funding growth, the Government could adopt a more flexible approach that allows for periodic reviews and adjustments based on actual needs and economic conditions. This would involve setting a baseline growth target but allowing for deviations when justified by increases in demand or cost pressures.

  • Rationale: This approach maintains a focus on sustainability while ensuring that the Scheme can adapt to changing needs and circumstances, preventing underfunding that could harm participants.

Inclusive and Adaptive Eligibility Criteria

Proposal: Implement a dynamic eligibility assessment process that regularly reviews and updates criteria based on the latest evidence and feedback from participants and experts. Ensure that the criteria are inclusive and do not unduly exclude individuals who need support.

  • Rationale: This ensures that the NDIS remains accessible to those who need it most while maintaining flexibility to adapt to new information and changing needs.

Enhanced Flexibility in Fund Utilization

Proposal: Allow participants to tailor their support plans within broad budget categories while providing clear guidelines and safeguards to prevent misuse. Encourage the use of individualised planning tools and support coordinators to help participants maximise the benefits of their budgets.

  • Rationale: This maintains the intended flexibility of the new budget approach while ensuring that participants retain control over their support plans and can access the specific services they need.

Balanced Fraud Prevention Measures

Proposal

Implement targeted fraud prevention measures that focus on high-risk areas without imposing excessive burdens on participants.

Utilise advanced data analytics and inter-agency collaboration to detect and address fraud efficiently.

Rationale:

This ensures the integrity of the NDS while minimising the impact on participants and maintaining a supportive, trust-based relationship between the Scheme and its users.

  • Genuine and Transparent Co-Design

Proposal:

Establish formal mechanisms for ongoing consultation and co-design with persons with disabilities and their representative organisations. Ensure transparency in the legislative process and provide regular updates and opportunities for feedback.

Rationale:

This fosters trust and collaboration, ensuring that the voices of persons with disabilities are heard and that the resulting policies are well-informed and effective.

Conclusion

The alternative argument presents a balanced approach that addresses the underlying assertions of the Bill while ensuring that the NDIS remains both sustainable and responsive to the needs of its participants. By adopting flexible, inclusive, and transparent measures, the Government can enhance the effectiveness and fairness of the NDIS, aligning it more closely with international standards and the expectations of the disability community.

How the Bill Deals with Diversity

The National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill 2024 aims to address various issues within the NDIS, including those related to diversity. However, the extent to which it effectively addresses diversity depends on how its provisions are implemented and interpreted. Here are some aspects of how the Bill deals with diversity:

1. Eligibility Criteria and Access to Supports

Key Provisions:

The Bill introduces new definitions and processes for determining eligibility for the NDSI, focusing on two streams: early intervention and disability requirements.

By clarifying these criteria, the Bill aims to ensure that supports are directed to those most in need, potentially benefiting diverse groups who might have been previously overlooked or faced barriers to accessing services.

Considerations:

Ensuring that the eligibility criteria are inclusive and culturally sensitive is crucial. This includes recognising the diverse needs of people with disabilities from different backgrounds, including Indigenous Australians, culturally and linguistically diverse (CALD) communities, and those in remote or rural areas.

Flexible Use of Funds

Key Provisions:

The shift from “reasonable and necessary supports” to “reasonable and necessary budgets” allows for greater flexibility in how participants can use their funds.

This flexibility could enable participants from diverse backgrounds to tailor their support plans to better meet their unique cultural, linguistic, and social needs.

Considerations:

It is important to ensure that participants have access to culturally appropriate services and that the flexibility in fund use includes options for supports that are specific to their cultural or community contexts.

Quality and Safeguarding Amendments

Key Provisions:

The Bill includes amendments to quality and safeguarding provisions, such as approving quality auditors and expanding infringement notice powers.

These measures aim to enhance oversight and ensure that all participants, regardless of their background, receive high-quality and safe services.

Considerations:

Quality and safeguarding measures should include standards and practices that are culturally competent and responsive to the needs of diverse communities.

Co-Design and Participation

Key Provisions:

The Bill emphasises the importance of involving people with disabilities in the legislative process through genuine co-design.

This involvement aims to ensure that policies and practices reflect the diverse experiences and needs of all NDIS participants.

  • Considerations:

Genuine co-design should include a diverse range of voices, ensuring that the perspectives of Indigenous Australians, CALD communities, and other marginalised groups are represented and heard.

This requires proactive engagement strategies and mechanisms to facilitate the participation of diverse groups.

  • Potential Weaknesses in Addressing Diversity

Despite these provisions, there are potential weaknesses in how the Bill addresses diversity:

  • Implementation Gaps:

The effectiveness of the Bill in addressing diversity depends heavily on its implementation. Without specific measures to ensure cultural competence and inclusivity, the intended benefits may not be fully realised.

  • Cultural Sensitivity:

There is a risk that the streamlined eligibility criteria and new assessment processes may not fully consider the cultural and contextual factors that affect the experiences and needs of diverse communities.

  • Access to Information and Support:

Diverse groups may face barriers in accessing information about the NDIS and navigating the system. The Bill should ensure that information and support services are available in multiple languages and accessible formats.

  • Representation in Co-Design:

Ensuring genuine co-design requires deliberate efforts to include diverse voices. There may be challenges in achieving meaningful representation from all segments of the disability community.

Alternative Approaches to Strengthen Diversity Considerations

  • Culturally Competent Assessments and Supports:

Implement culturally competent assessment processes that consider the unique needs and contexts of participants from diverse backgrounds.

Ensure that support options include services that are culturally appropriate and accessible.

  • Inclusive Policy Development:

Establish formal mechanisms for ongoing consultation and co-design with representatives from diverse communities, including Indigenous Australians, CALD groups, and people from rural and remote areas.

Ensure that these consultations are transparent, and that feedback is incorporated into policy development.

  • Targeted Outreach and Support:

Develop targeted outreach programs to raise awareness about the NDIS and its services among diverse communities.

Provide support services, including translation and interpretation, to help participants from diverse backgrounds navigate the NDIS system.

Monitoring and Accountability:

Implement monitoring and evaluation mechanisms to assess the impact of the Bill on diverse communities.

Ensure accountability by regularly reporting on how the NDIS is meeting the needs of participants from diverse backgrounds.

Conclusion

While the National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No.

  1. Bill 2024 includes provisions that can potentially benefit diverse communities, its effectiveness will depend on how these provisions are implemented and whether they are inclusive and culturally sensitive. By adopting alternative approaches that prioritise cultural competence, inclusive policy development, targeted outreach, and robust monitoring, the Government can strengthen the Bill’s ability to address the needs of all NDIS participants, ensuring that the Scheme is truly equitable and accessible.

The National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill 2024 aims to address various issues within the NDIS, including those related to diversity. However, The extent to which it effectively addresses diversity depends on how its provisions are implemented and interpreted. Here are some aspects of how the Bill deals with diversity:

1. Eligibility Criteria and Access to Supports

Key Provisions:

  • The Bill introduces new definitions and processes for determining eligibility for the NDIS, focusing on two streams: early intervention and disability requirements.

By clarifying these criteria, the Bill aims to ensure that supports are directed to those most in need, potentially benefiting diverse groups who might have been previously overlooked or faced barriers to accessing services.

Considerations:

Ensuring that the eligibility criteria are inclusive and culturally sensitive is crucial. This includes recognising the diverse needs of people with disabilities from different backgrounds, including Indigenous Australians, culturally and linguistically diverse (CALD) communities, and those in remote or rural areas.

2. Flexible Use of Funds

Key Provisions:

  • The shift from “reasonable and necessary supports” to “reasonable and necessary budgets” allows for greater flexibility in how participants can use their funds.

Flexibility

This flexibility could enable participants from diverse backgrounds to tailor their support plans to better meet their unique cultural, linguistic, and social needs.

Considerations:

It is important to ensure that participants have access to culturally appropriate services and that the flexibility in fund use includes options for supports that are specific to their cultural or community contexts.

Quality and Safeguarding Amendments

Key Provisions:

The Bill includes amendments to quality and safeguarding provisions, such as approving quality auditors and expanding infringement notice powers.

These measures aim to enhance oversight and ensure that all participants, regardless of their background, receive high-quality and safe services.

Considerations:

Quality and safeguarding measures should include standards and practices that are culturally competent and responsive to the needs of diverse communities.

Co-Design and Participation

Key Provisions:

The Bill emphasises the importance of involving people with disabilities in the legislative process through genuine co-design.

This involvement aims to ensure that policies and practices reflect the diverse experiences and needs of all NDIS participants.

Considerations:

Genuine co-design should include a diverse range of voices, ensuring that the perspectives of Indigenous Australians, CALD communities, and other marginalised groups are represented and heard.

This requires proactive engagement strategies and mechanisms to facilitate the participation of diverse groups.

Potential Weaknesses in Addressing Diversity

Despite these provisions, there are potential weaknesses in how the Bill addresses diversity:

Implementation Gaps:

The effectiveness of the Bill in addressing diversity depends heavily on its implementation. Without specific measures to ensure cultural competence and inclusivity, the intended benefits may not be fully realised.

Cultural Sensitivity:

There is a risk that the streamlined eligibility criteria and new assessment processes may not fully consider the cultural and contextual factors that affect the experiences and needs of diverse communities.

Access to Information and Support:

Diverse groups may face barriers in accessing information about the NDIS and navigating the system. The Bill should ensure that information and support services are available in multiple languages and accessible formats.

Representation in Co-Design:

Ensuring genuine co-design requires deliberate efforts to include diverse voices. There may be challenges in achieving meaningful representation from all segments of the disability community.

Alternative Approaches to Strengthen Diversity Considerations

Culturally Competent Assessments and Supports:

Implement culturally competent assessment processes that consider the unique needs and contexts of participants from diverse backgrounds.

Ensure that support options include services that are culturally appropriate and accessible.

Inclusive Policy Development:

Establish formal mechanisms for ongoing consultation and co-design with representatives from diverse communities, including Indigenous Australians, CALD groups, and people from rural and remote areas.

Ensure that these consultations are transparent, and that feedback is incorporated into policy development.

Targeted Outreach and Support:

Develop targeted outreach programs to raise awareness about the NDIS and its services among diverse communities.

Provide support services, including translation and interpretation, to help participants from diverse backgrounds navigate the NDIS system.

Monitoring and Accountability:

Implement monitoring and evaluation mechanisms to assess the impact of the Bill on diverse communities.

Ensure accountability by regularly reporting on how the NDI$ is meeting the needs of participants

Conclusion

While the National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No.

  1. Bill 2024 includes provisions that can potentially benefit diverse communities, its effectiveness will depend on how these provisions are implemented and whether they are inclusive and culturally sensitive. By adopting alternative approaches that prioritize cultural competence, inclusive policy development, targeted outreach, and robust monitoring, the Government can strengthen the Bill’s ability to address the needs of all NDIS participants, ensuring that the Scheme is truly equitable and accessible.

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