Concerns regarding reassessment restrictions and participant safety

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1064

Submission regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

I am writing as a Support Coordinator working directly alongside NDIS participants and families in South Australia.

I acknowledge the importance of ensuring the long-term sustainability of the National Disability Insurance Scheme (NDIS) and recognise the need to address fraud, exploitation, poor practice, and inconsistencies across the Scheme. However, I hold significant concerns regarding aspects of the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 and the practical impact these proposed changes may have on vulnerable participants.

My concerns are centred around participant safety, procedural fairness, accessibility, independent oversight, and the capacity of highly vulnerable individuals to safely navigate increasingly restrictive systems.

Support Coordination and reassessment restrictions

The proposed reassessment restrictions are deeply concerning from a practical frontline perspective.

Many participants I support live with intellectual disability, psychosocial disability, acquired brain injury, autism, executive functioning impairments, trauma related barriers, communication difficulties, cognitive impairment, or highly limited informal supports. In practice, many participants are unable to independently identify when reassessment is required, gather evidence, complete forms, communicate functional deterioration, or effectively advocate for themselves within complex administrative systems.

Support Coordinators often play a critical role in:

identifying deterioration and escalating risk,

coordinating allied health evidence,

facilitating communication between stakeholders,

assisting participants to understand processes,

and preventing crises through early intervention.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1064

Restricting reassessment requests to participants, nominees, or child representatives may unintentionally create significant barriers for participants who rely heavily on external support to safely navigate the Scheme.

In my experience, reassessment requests are often not driven by opportunistic funding increases, but by genuine deterioration, safeguarding concerns, carer breakdown, housing instability, escalating behavioural risks, declining mental health, or increased functional impairment.

Preventative intervention frequently prevents:

hospitalisation,

homelessness,

emergency service involvement,

restrictive practices,

carer collapse,

or admissions into more restrictive settings.

I am concerned the proposed requirement for changes to be “significant and ongoing” may result in participants deteriorating substantially before supports can be adjusted.

Practical example

I support participants who would likely never independently request reassessment despite experiencing significant deterioration in functioning or escalating risk.

For example, participants with psychosocial disability and intellectual disability may minimise risk, disengage from services, avoid communication, or lack insight into their own deterioration. In several cases, early intervention through coordinated reassessment processes has prevented hospitalisation, homelessness, self neglect, and significant safeguarding concerns.

Without practical assistance navigating these systems, many vulnerable participants would not successfully access reassessment pathways independently.

Reduction in reviewability and oversight

I hold serious concerns regarding the narrowing of reviewable decisions and the reduced role of independent merits review through the Administrative Review Tribunal.

Independent oversight is a critical safeguard within systems supporting vulnerable Australians. While consistency and sustainability are important goals, participants must retain meaningful and accessible pathways to challenge decisions that significantly impact their safety, wellbeing, independence, and access to support.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1064

I am paiiicularly concerned by the increasing reliance on legislative instrnments and mechanisms that reduce funding categories without meaningful individual merits review.

From a frontline perspective, paiiicipants aheady experience substantial difficulty understanding:

□ plan decisions,

□ reassessment pathways,

□ review rights,

□ and administrative processes.

Reducing practical review pathways may dispropo1iionately disadvantage paiiicipants with:

□ cognitive impaiiments,

□ psychosocial disability,

□ intellectual disability,

□ trauma histories,

□ communication difficulties,

□ and liinited advocacy capacity.

“Directly arising” support needs

I also hold serious concerns regai·ding the proposed requii·ement for suppo1is to ai·ise “dii·ectly” from impaiiments that met access criteria.

Paiiicipants do not experience disability in isolated categories. Many individuals experience highly interconnected presentations involving autism, trauma, psychosocial disability, nemological conditions, chronic illness, intellectual disability, executive functioning impai1ments, senso1y regulation difficulties, and fluctuating mental health.

In practice, these conditions compound one another and significantly impact functional capacity.

A naiTow inte1pretation risks excluding legitiinate disability-related suppo1is simply because an individual’s presentation is complex and interconnected.

I am concerned this may dispropo1iionately affect:

□ paiiicipants with psychosocial disability,

□ individuals with trauma histories,

□ people with acquii·ed disability,

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1064

participants with fluctuating conditions,

and individuals with multiple interacting impairments.

Ministerial powers and support determinations

I hold concerns regarding the proposed powers allowing broad reductions to categories of supports through legislative instruments.

While I acknowledge the importance of Scheme sustainability, reductions to support categories such as social and community participation may have serious unintended consequences for participant wellbeing, mental health, social inclusion, independence, and safeguarding.

For many participants, social and community participation supports are not discretionary lifestyle supports. They are often the primary mechanism preventing:

severe isolation,

mental health deterioration,

self-neglect,

carer dependence,

behavioural escalation,

and institutionalisation.

For participants with psychosocial disability, autism, intellectual disability, or complex trauma, community participation frequently forms a critical component of maintaining functioning, structure, emotional regulation, social connection, and independence.

Reducing these supports broadly across participant groups without individualised consideration may create downstream pressure on:

hospitals,

crisis systems,

emergency services,

housing systems,

families,

and state-based mental health services.

I am also concerned about the limited practical capacity for participants to challenge broad reductions implemented through legislative instruments.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1064

Parental responsibility and informal supports

I also hold concern regarding increasing emphasis on parental responsibility and info1mal supports within the Scheme.

Families and carers are aheady experiencing significant levels of burnout, financial pressure, emotional exhaustion, and long-tenn caring responsibilities.

In my experience, many families continue providing extensive unpaid care far beyond what would ordinarily be considered reasonable parental or infonnal suppo1i expectations.

Increasing reliance on infonnal suppo1is without adequate recognition of caregiver burnout risks:

□ family breakdown,

□ withdrawal from workforce paii icipation,

□ deterioration in carer mental health,

□ and reduced long-tenn sustainability of info1mal support networks.

For many paiticipants, paiiicularly children and young people with high suppo1i needs, info1mal suppo1ts ai·e aheady stretched beyond safe and sustainable capacity.

Participants losing access to the Scheme

I hold significant concern regai·ding future access refo1ms, pennanence requirements, and references to “all appropriate treatm ent”.

Many disabilities, particulai·ly psychosocial disabilities, neurological conditions, trallllla-related conditions, and fluctuating impaiiments, do not follow straightfo1wai·d treatment pathways.

I am concerned these provisions may unintentionally create baITiers for paii icipants who:

□ cannot tolerate ce1iain treatments,

□ have ah-eady experienced treatment failure,

□ experience fluctuating capacity,

□ or whose iinpaiiments remain significantly disabling despite intervention.

I am also concerned paiiicipants may disengage from the Scheme due to fear, confusion, administrative burden, or inability to navigate increasingly complex systems.

Paiiicipants with the least capacity to advocate for themselves are often those most at risk of falling through systemic gaps.

Automated decision-making

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1064

I hold concerns regarding the expansion of automated decision-making processes within the NDIS.

Paiiicipants within the Scheme frequently experience vulnerability, trauma, cognitive impai1ment, communication baITiers, and difficulty navigating administrative systems.

Strong safeguards, transparency, meaningful human oversight, and accessible review pathways ai·e essential to ensure automated systems do not unintentionally disadvantage vulnerable paiiicipants.

Administrative efficiency must not come at the cost of paiiicipant safety or procedural fairness.

Conclusion

I strongly suppo1i effo1is to improve the integrity and sustainability of the NDIS. However, sustainability must remain balanced with participant safety, accessibility, dignity, and independent oversight.

I respectfully urge the Government to:

□ preserve meaningful review pathways,

□ strengthen safeguai·ds smTounding reassessment restrictions,

□ ensure Suppo1i Coordinators and trusted supports can continue assisting vulnerable paiiicipants with reassessment processes,

□ reconsider the wording and application of the a€redirectly ai·isinga€□ suppo1i test,

□ implement strong safeguards around automated decision-making,

□ ensure broad funding reductions cannot occur without meaningful oversight and consultation,

□ and recognise the critical role that social and community participation suppo1is play in preventing crisis and maintaining independence.

The NDIS was established to suppo1i Austi·alians with pe1manent and significant disability to live safely, independently, and with dignity within their communities. I urge the Government to ensure future refonns preserve these principles.

Kind regards,