NDIA Accountability Project

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Autism diagnosis and plan management experience (Participant experience)

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

Submission - NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026

SUBMISSION National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submitted by: Samuel Broadbent NDIS Participant | Brisbane, Queensland Date: May 2026

National Disability Insurance Scheme Amendment

Submission: NDIS Amendment - Securing the NDIS for Future Generations Bill 2026 Submission No.: 1414

uncontrolled growth in plans“; That in January 2026 national cabinet agreed to reduce annual cost growth “to five per cent”, six percent lower.“ And that mainstreaming supports around has eroded. around this NDIS The right response is rebuild ship re-fund energise mainstream and community support so it’s one part properly designed disability ecosystem whole of it wrong response throw participant overboard before rebuilding finished Memorandum itself acknowledges proposed reforms if not sequenced may appear retrogressive terms they will unless foundational supports government promised exist when individualised supports reduced This submission makes following overarching points:

  • I strongly support fraud integrity enforcement measures Schedule (Parts) including amended provider definition expanded compliance powers under Regulatory Powers Act civil penalty regime record keeping obligations, claim window Fraud harms participants directly dollar lost someone needs every dollar denied

oppose design single-instrument functional capacity assessment regime (Schedule Part) relies on a test administered non-clinician processed automated decision-making tool Single day by unqualified person cannot capture fluctuating contextual nature of particular people autism intellectual ADHD psychosocial conditions led collapse Independent Assessments proposal -oppose any narrowing access autistic adults driven containment rather than evidence need Diagnosis-based culling breach original promise Scheme CRPD Articles opposition better governance plan management principle oppose panel model consolidates into small number very large providers My lived experience opposite framing page 70–71: Large providers treated me as numbers locally based with strong technology gave best experience margin -strongly oppose reform diminishes role coordinators folds functions Local Area Coordinator LAC model Support coordinators been most consequential element my plan; in experience have not. cuts social and community participation funding Comparisons against baselines misleading because life shut down COVID Reductions here without parallel investment mainstream infrastructure National Agreement Foundational Supports will isolate participants whose mental physical health depend engagement inconsistent Article 26

Submission - NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission: 7. I support the principle of restoring foundational and mainstream supports but I urge Parliament to sequence reform so that mainstream community supports are demonstrably in place before individualised supports\nis withdrawn Build ship lifeboats removed.

National Disability Insurance Scheme Amendment

Submission: Submission - NDIS Amendment Bill Securing Future Generations NDIS Review Action Schedule Parts Eligibility Permanence Test All Appropriate Treatment Concept Introduced Under Consistent With Must Not Be Used Remove Access Autistic Adults People Lifelong Neurodevelopmental Conditions Curative Sense Clinically Meaningful Narrowing Of Access Binding Statutory Commitment To The National Agreement On Foundational Supports Operational Before Exits Commence Memorandum Acknowledges Retrogressive Risk CRPD Article Sequencing Safeguard Answer Recommendation Plan Reassessments Limit Unscheduled Plan Reassessments Genuine Ongoing Changes Need Restrict Requests Participants Authorised Representatives Memorandum Concern Lodged Without Participant’s Knowledge However Exception Created Circumstances Where Participant’s Plan No Longer Reflects Clinical Evidence New Functional Capacity Assessment Treating Clinician Reassessment Door Sealed Shut Protections Run Both Ways Against Unwanted Reassessments Override Clinical Evidence Support Coordination Preserve Distinct Funded Support Separate From LAC Functions Recognisation (Page Intermediaries Have, In Some Cases, Lodged Unscheduled Reassessments Without Tightening Who Can Lodge Reassessment Diminishing Role Government Commission Independent Review LAC Performance Resourcing Transfer Any Support Coordination Functions LACS Plan Management Panel Arrangement For Plan Managers Explicitly Include Capacity Small Mid-Sized Plan Managers Meet Quality Integrity Standards Exclusive Large National Providers Reduce Improve Participant Outcomes Direct Contrary My Lived Experience Across Multiple Plan Managers Prohibition Plan Managers Providing Other NDIS Supports Same Participant Conflicts Interest Market Real Selection Criteria Payment Turnaround Standards Participant Communication Standards Response Within One Business Day Invoice Visibility For Participants Page 4 of 18

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

Submission 1414

Submission – NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026

Recommendation 7—Social and community participation

  • Reductions in the social and community participation support category should be deferred until mainstream community infrastructure (peer-led mental health hubs, social enterprises, accessible transport) is demonstrably in place. The Memorandum itself ties this category of supports to CRPD Articles 19(living independentlyand being includedinthecommunity) an(d\n ofhabilitationandrehabilitation)—reductionsaheadofreplacementinfrastructurewould put Australiaina breach oft hose obligations inp ractice.
  • The Agencyshouldnotuse2020spendingasa baselineforanycomparison—itreflectsa pandemic,n ot a steady state.

Recommendation 8-Fraud,integrityande nforcement(Schedule 2,Parts (Parts{ }1– {5}an d}{7})

  • IsupportScheduleIn substance:theadmendeddefinitiono fNDISprovider,civilpenalties ,expandedinformation-gatheringpowers,re cordkeepingobligationsandth e90-dayclaim window. -IurgetheGovernmentanda ndMinistertocommunicatefraud reformproportionately.Public messagingthatdispropor tionatelyemphasises fraudstigmatisesparticipantsando ngood providerswhoserveth em.Theheadlinestoryshoul dbethe livesthenDISHaschanged . ### Recommendation 9-Sequencing and the

My Story – Lived Experience of the NDIS

I am 28 years old.

Life before the NDIS - the “lottery”

The years before the NDIS, in my experience as Queensland operated state funding existed; whether dependent upon your name coming out draw While I waited while family leaned community organisations churches not-for-profits small local services ran goodwill volunteers dwindling resources charitable funders those did extraordinary work but running hugs kisses used put them could system people trying hardest Eventually number called received some state funding person assigned administer little beyond collecting commission That immediately NDIS arrived postcode-and-luck getting help depended who knew side arbitrary line happened fall passage relevant mainstream foundational supports framework Schedule Part human rights statement at pages : any reform narrows individualised entitlement without parallel investment main stream community supports risks returning participants pre-Scheme state ## Australia’s commitment —the CRPD and Gillard reform Australia signed Convention on Rights Persons Disabilities original signatories agreed country give effect to Article living independently included in community) (Article adequate standard living social protection active involvement disability developing law policy concerns them freedom exploitation violence abuse NDIS legislative embodiment commitments early architects Scheme visionaries designed Government legislated took genuine political courage deliver most ambitious century Explanatory Memorandum acknowledges lineage page recording idea national disability insurance program recommended through summit… held April Productivity Commission’s report Disability Care Support became blueprint This directly Statement Compatibility Human Rights Memoranum against every provision Bill must measured

Entering the NDIS – minimal funding, real risk

When the NDIS came to Queensland, I was automatically rolled over from state funding. My first plan was minimal. It helped, but I was still leaning heavily on the goodwill of others to live a viable life. Around the same time, tensions at home escalated. Family and domestic violence proceedings were brought, in which I was the person subject to an order against the background of household in which I lived. I made many trips emergency departments; admitted hospital several times discharged sooner than should have been because bed needed; eventually kicked out due to lack resources. Living alone with minimal NDIS funding struggled daily tasks other people take granted—cooking proper meals keeping place clean attending basic hygiene.Public transport largely inaccessible for me.I few friends call.My therapy supports helpful every hour consumed simply getting appointments.There nothing left living.This experience directly relevant Schedule Bill functional capacity access single-instrument assessment cannot capture disability interacts safety housing isolation real-time too-low-plan context not merely administrative outcome it CRPD Article (freedom exploitation) abuse) and Article 28(adequate standard-of-living issue). The first cut progress undone $300 loan year followed received slightly larger stabilised no longer surviving takeaway pizza flat could look after small amount support beginning function consolidate that progress give Agency clinical evidence kept asking commissioned comprehensive functional capacity assessment qualified clinician The cost over $300 Centrelink payments alone took personal loan repayments strained budget months afterwards describe detail because as currently drafted would shift functional capacity system run by Agency—but trialled cohort does address how legitimate clinical assessments where one is required Commonwealth bear costs any functional capacity assessment required underpins Recommendation particularly sub- cost of any functional capacity assessment required for access or plan purposes. Despite the clinical assessment, agency reduced my plan.The progress I had made was abandoned forced move home whatever support get Explanatory Memorandum(Schedule Part )frames reassessment reform way stop unscheduled

National Disability Insurance Scheme Amendment

Submission — NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1414

reassessments being lodged “without a participant’s knowledge,” often by third parties. I understand that problem but participants also need protection from reverse harm—the Agency reassessing plans downwards despite clinical evidence paid for, such protections must run both ways This experience directly relevant schedule part bill plan re-assessment supports Recommendation including proposed exception where no longer reflects clinical evidence. turning corner role Support Coordinator Things began improve when funded coordinator My support pushed back decisions did not match needs prepared evidence helped escalate to Administrative Review Tribunal road left She connected me social groups liaised with university secured study needed health professionals first time making real progress help build small team trust When have Problem worker call anyone else I am asked imagine without LAC function cannot conscience support advice inconsistent generic LACs do proximity know Me my support does this experience directly relevant planning provisions Schedule Memorandum frames implementing NDIS Review Recommendation navigation function and supports recommendation preserve distinct funding coordination system stands today fragile dependent others Today varied May totals $158,142.66 period November Core Flexible Supports Relationships Choice Control Behaviour Finding Keeping Job Improved Daily Living Coordination situation more stable secure live grandparents ageing NDIS-funded workers take appointments develop household skills still learning late twenties through University degree stated goals graduate find employment Develop Social Skills routines obtain independent housing strengthen mental Health stronger relationship network Each those consistent CRPD’s Article 19 vision of living inclusion current shape most amended Bill: access functional capacity Planning provider regulation management automated decision-making used in context

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

Submission 1414

Submission – NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026

I do not pretend the Scheme should fund everything in my life. I am saying the opposite —the Scheme has built something remarkable,and the Governmentshouldnotteardownthefoundationsbefore thereplacementstructureisbuilt.Thequestionthathauntsmeissimple:whathappenswhenmy grandparentsareno longerhere?If Ihavetoliveindependentlyagain,wil lbe supported—orlefttosqualorawayinthewayIconceewas?Thatquestionspeaksdirectlyto Recommendationofthis submission—theproposedstatutorysequencingrulethenoindividualisedsupportreductioncantakeeffectuntilequivalentmainstreamandfoundationalsupportsareroptionalfortherelevant cohort,consistentwiththememorandum’sownCRPDArticle(2commitmentatpages–.

Comments on the Bill

The remainder of this submission addresses specific measures in the Bill against the framework of the Explanatory Memorandum, the CRPD, and the 2023 NDIS Review. I have grouped my comments by theme and where possible matched them to relevant Schedule, Part item.

Fraud integrity enforcement strongly supported

I begin what support because without reservation supports it The Explanatory Mem is candid about Scheme’s weaknesses at page states National Disability Insurance Agency does not necessary powers regulate monitor payment over $5 billion per year It draws findings Australian National Audit Office’s 2019 Fraud Control Program report Disability Royal Commission proposes coherent package amended provider definition expanded compliance Powers Regulatory Provisions Act new civil penalties mandatory record retention day claim window panel arrangement for with prohibition conflicts interest supports these substance Minister Butler second reading speech every dollar obtained through fraud participant who needs it also reaches beyond participants damages families friends wider community providers work properly applaud Fusion Taskforce additional powers penalty deterrents consistent Government human rights statement under Memorandum that engages Article exploitation violence abuse strengthened oversight Australia obligations respectful caution government media Fraud fraction cost pressures scheme commands disproportionate share public conversation people life routinely tell me heard NDIS fraud almost never lives changed risk overweighting narrative stigmatises participants many good faith practice undermines public consent requires right based scheme CRDP ask Government communicate reform proportionately address but lead dignity inclusion story built on

Plan management reform (Schedule part principle opposed design managed modes available current Act self-managed planAgencymanaged multiple managers within managemen

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

Submission 1414

Submission – NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026

category. My experience leads me to a different conclusion to the one set out at pages 70– 71of the Explanatory Memorandum which identifies smaller plan managers as more likely to exhibit risk factors for conflicts-of-interest collusion fraud poor record-keeping.

Self-management

I self-managed several years I valued control knew providers were being paid when from budget As my grew complexity it reached point needed help keep up reasonable necessary what was claimable category how kept books straight moment moved planned management.

Large national plan manager—my worst experience

First plan managed large company outsourced much back-office work overseas small Australian-based team handled inquiries dominant experience sending resending invoices sometimes weeks waiting two six weeks provided paid provider had over participants To credit ran strict firewall between its plan management arm and therapy arm conflict interest discipline did not Everything else did not. Moved second larger plan manager expecting scale meant better systems It did not Providers chased payments. Chased Plan Manager Switched again about year .

A small local plan manager — My best experience

Current plan is small local with around hundred participants bookkeeping background They have named responsible account Invoices submitted Monday tend be paid Thursday can text get response within hours Can see real time where every invoice sits workflow If want hold placed on Invoice place hold until clear once approve processes same day Consistently say this most efficient communicative they deal that the raises queries promptly wrong. Cannot square experience Memorandum’s framing at pages 70– 19 expressly contemplates having “the opportunity to choose their residence live… are obliged particular living arrangement.” Plan choice a corresponding economic-life expression of autonomy. Agency management – The most opaque three

National Disability Insurance Scheme Amendment

Submission: Submission - NDIS Amendment Securing the NDIS for Future Generations Bill 2026

I have also been Agency-managed.

Providers were paid on time but had no visibility into what was claimed against their plan when asked about invoices or bills via participant portal due to lack thereof. This arrangement creates conditions where over-claiming fraud can occur because nobody who knows participants is checking expenditures directly. Reform must not treat agency management lightly despite Schedule’s integrity case applying equally as much here; thus, reform should address this issue seriously.

National Disability Insurance Scheme Amendment

Submission - NDIS Amendment: Securing the NDIS for Future Generations Bill 2026

Submission says these provisions “will make way for implementation of standardised evidence-based assessments impacting day-to-day living moving away from current diagnosis.” Schedule separately permits automated decision-making within with protections. These point toward regime where single instrument administered processed part automatically determines access entitlements.

This is path abandoned:

The previous Government proposed Independent Assessments mandatory functional capacity assessed contracted allied health professionals gateway funding following coordinated submission process Joint Standing Committee on NDIS corroborating advice statutory Independent Advisory Council refusal State Territory Reform Ministers support proposal model was abandoned July Minister Reynolds confirmed independent assessments currently understood dead arguments that produced reversal were tool validity (instruments validated participants psychosocial disability autism intellectual culturally and linguistically diverse backgrounds); process integrity substantial contracts let pilot evaluated cohort-harm children regional remote Aboriginal Torres Strait Islander absence appeal assessment itself. I urge Parliament not re-legislate same model under different name Evidence base led to this change has not changed Recommendation action Memorandum cites authority Schedule Part did recommend navigator-supported holistic approach recommended should be amended reflect what NDIS Review actually said.

What one-shot, single-tool assessment feels like I recently sat through trial Support Needs Assessment SNA appeared form Agency proposes want describe experience honestly because policy debate abstractly conducted.

Assessment exhausting By end would say almost anything allowed leave denied opportunity give complete account myself format permitted moments when made worse sustained attention social demand verbal recall precisely domains struggle measurement function places measured endurance occupational therapist completing domain testing typically spread over multiple sessions triangulate across measures such WHODAS Vineland Adaptive

National Disability Insurance Scheme Amendment

Submission: Submission - NDIS Amendment Bill Securing the NDIS Future Generations 2026

Behavior Scales carer-needs scales would interpret results clinical context.

Bill compresses event completed person training Agency’s own description administering instrument — disability practice say disparage employed work because will be asked discipline allied health says format well can’t done.

Why “one person autism autistic” matters here

There saying community met you have met two broadly similar presentations describe themselves differently might algorithm understands get supports need other language they actually use filter out assessors interpretation how choose translate participant answers data field single instrument becomes series small judgements masquerading number.

Need fluctuates — Access cannot shot gate

A second concern structural functional capacity changes over time sometimes upward downward almost always non-linearly precisely why existing framework provides plan reassessment regime fixes participants entitlement on test day mood night sleep high bar revisit reality disability inconsistent Tune Review finding permanence poorly suited to psychosocial disability.

Automated decision-making (Schedule items)

support transparency audit clear standard operating procedures Memorandum flags do not support automated decisions operational default access eligibility minimum should amended provide right human review adverse outcome plain-English statement reasons including inputs weights independent annual bias against cohorts predictably disadvantaged by algorithmic decision making,including people with intellectual and culturally linguistically diverse participants. Memoranum recognises pages 153 –– that Article of CRPD requires active involvement implementation legislation concerns them – systems engineered without this involvement satisfy in substance.

Permanence all appropriate treatment Schedule Part introduces concept clarifies permanent NDIS action I oppose clarification opposed removal access for whom curative sense clinically inappropriate Autism treated out many psychosocial .

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

Submission 1414

Submission – NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026

neurological conditions follow that pattern too. If “all appropriate treatment” is intended to mean clinically reasonable management consistent with the participant’s goals, the Act should say so. If it is intended to be a cost-containment lever, the Parliament should be honest about that and Parliament should reject its. The Memorandum’s own human rights statement (page 162-163) treats access changes as engaging Article 4(2) CRPD’s progressive realisation duty; a clarification that operates as a removal mechanism is at risk of being retrogressive in fact, even if non-retrogressive in form.

Social and community participation—build before you cut I have heard the Agency cite a tripling of social and community participation spending over the last five years, with 2020 as a frequent reference point. With respect, 2020 is not a baseline. 2020 was a public health emergency in which community life was shut down. People like me—who already find friendship difficult—are locked at home and forgotten. The mental and physical health consequences for participants were severe.Social and community participation is, in many ways, the most normalising part of my plan. It allows me to attend concerts or films join groups simply leave house That precisely kind inclusion Scheme built deliver direct domestic expression article 19 support Government doing peer-led mental hubs enterprises these exactly kinds infrastructure replace individualised funding But sequencing must right Do not cut individuals budget before community infrastructure exists them participate

Closing

The NDIS was the most ambitious social policy of this century, and it is one of the things I am proudest of as an Australian. I am the kind of person it was built for. I am also the kind of person who, in the system that preceded it, would not have been served. I do not want to go back there, and I do not believe the Parliament does either. I support a Bill that addresses fraud, restores the Scheme’s original intent, and re-energises the mainstream and community supports that should sit around it. I do not support a Bill that, in the name dof sustainability, reduces eligibility, narrows entitlement, and replaces the judgement of clinicians and trusted intermediaries with a single test and an algorithm. The Bill before the Parliament is, in many respects, the right reform. It can be the right reform in every respect with the amendments set out inthis submission —amendmentsthatrespecttheoriginalintentofthescheme,theGovernment’sown commitments under the NDIS Reviewandthenational Agreement on Foundational Supports,and Australia’s obligationsundertheconvention On therightsOf PersonswithDisabilities.Thank youfortheadportunitytomake thissubmission.IamwillingtoappearbeforetheCommittee if thatwouldassist.

Respectfully, Samuel Broadbent NDIS Participant Brisbane,Queensland

Sources and references

This submission draws on the following primary sources. References to “the Memorandum” in the body are references to the Explanatory Memorandum to the Bill.

  • The explanatory memorandum for the National Disability Insurance Scheme amendment bill is particularly useful: it covers an overview, a statement about compatibility with human rights from pages 152–163; schedule one which discusses access planning including original intent up until page twelve within this scheme’s context); Schedule two part six regarding plan management found between seventy through eighty-one inclusive), along historical background starting around paragraph number seventeen-two till eighteen-five .
  • Convention On Rights Of Persons With Disabilities(CRPD), especially articles three( general principles ), four-point-two progressive realization ,four-point-three consultation active involvement five equality non-discrimination sixteen freedom exploitation violence abuse nineteen living independently being included community twenty-two privacy twenty-six habilitation rehabilitation )and twenty-eight adequate standard life social protection). Australia signed CRPD year seven hundred eight-seven ratified same year nine-hundred-and-eleven respectively.
  • Independent Review into NDIS (NDIS review) final report working together deliver NDIS Professor Bruce Bonyhady AM Lisa Paul AO PSM recommendation actions thirty-one ninety-nine specifically mentioned.
  • Review of NDIA Act thirteen tune review David Tune AO PSM nineteen-nineteen.
  • Royal Commission on Violence Abuse Neglect Exploitation People disability final report twenty-thirty.
  • Australian National Audit Office National Disability Insurance Fraud Control Program nineteen-twenty-fourteen.
  • NDIS Provider Worker Registration Taskforce wade task force final report 2024.
  • Productivity Commission Disability Care Support Inquiry Report eleven and the product commission review costs fourteen-seventeen
  • Statement Minister Reynolds then minister for ndis july ninth two thousand twenty one independent assessments currently understood them dead following meeting reform ministers joint standing committee inquiry independent assessment submissions April twentieth twenty-one people with disabilities supplementary submission critique ndia independent assessment submission .
  • National Cabinet statement January twentysix agreeing reduce annual cost growth ndis five six percent lower recorded memorandum overview bill.
  • Senate Community Affairs Legislation Committee, Inquiries into national disability insurance scheme amendment getting back track number first second reports twenty-two.

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

Submission - NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 • My NDIS plan letter and varied plan (start date: November 2025*, varied:* May**-20***)**, referredencedforpersonalexperienceclaimsinthissubmission.