Submission to Senate Community Affairs Legislation Committee Inquiry

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

Table of Contents:

Submission to Senate Community Affairs Legislation Committee Inquiry … 1 National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 ….. 1 Table of Contents: ……. 1 Impact of the proposed NDIS legislation on gender equality, safety and the rights of women and girls ………….. 5 Supporting women’s meaningful participation and needs ……………………………………………………… 6 Reducing sexual and gender-based violence ……………………………………………………………………. 11 Supporting resilience, crisis, law and justice responses for women and girls ……………………. 13 Leadership and accountability…………………………………………………………………………. 14 Care and Support Workforce………………………………………………………………………. 15 Closing the Gap Outcomes potentially impacted by NDIS Reform …………………………………… 17 Closing the Gap Outcomes ………………………………………………………………………………………….. 18 Everyone enjoys long and healthy lives ………………………………………………………………………… 18 Children are born healthy and strong ………………………………………………………………………….. 19 Children thrive in their early years and access culturally appropriate early childhood education …… 19 Students achieve their full learning potential …………………………………………………………………. 20 Strong economic participation and development ……………………………………………………………… 21 Housing security …………………………………………………………………………………………………….. 21 Adults and young people are not overrepresented in the criminal justice system …………………. 22 Children are not overrepresented in the child protection system ………………………………………. 23 Families and households are safe …………………………………………………………………………………. 23 Social and emotional wellbeing ……………………………………………………………………………………. 24 People maintain a distinctive cultural, spiritual, physical and economic relationship with their land and waters ……………………………………………………………………………………… 24 Cultures and languages are strong, supported and flourishing ………………………………………………. 25 Impact on CALD Participants and Families ……………………………………………………………………. 25

Submission 1418

Safety Concerns Regarding the Proposed Assessment Model - Page: [2]

Recommendation:

General Recommendations ●

○ Human Rights, Safeguards & Security ◉

Choice of Controls ●

Assessments Process ●

Women & GBAV ●

Indigenous People ●

CALD Community ●

Foundations Support & Mainstream Service ●

####### Staffing Recommendations ● ######## Transitions & Implementations

National Disability Insurance Scheme Amendment Bill

Submission 1418

Trellis Mental Health

Dear Community Affairs Legislation Committee RE: NDIS Bill

RE: NDIS Bill

I am writing in my capacity as an Occupational Therapist in private practice whose work includes the NDIS.

• I work with people with psychosocial, nurodevelopmental,nurologicaland intellectual disabilities,manyof whom experience multiple complexdisabilities.I request thatthe proposed reforms do not passin their current form.Theproposed legislation hasthepotentialto exclude significantly morepeople from accessingremainingon then DIS thanthen currently estimatedparticipants expectedtoleave scheme.Theremovsintroducetomultiple changes to eligibility criteria reassessment processes yet there remains very limited information about how thesecriteria will be interpreted and applied inpactice.Inparticular,there is substantial concern regardingtheresponsibilityrequirementthat peoplemust have undertaken all appropriate treatments reducemovementimpairments.Maybe unable meet this requirement due cost access barriers medical risk trauma personal choice cultural considerations.At present therenoinformation insufficient clarity regardingswhat treatmentwould considered mandatory for reducing impairments autism,intellectual disability ,psychosocial disability neurological conditions deafness blindness other lifelong disabilitiesthelegislation also appears inconsistent several existing government commitments policies recommendations including recommendationsof Disability Royal Commission National Plan End Violence Against Women Children women Peace Security Agenda commitmenstowards Closing Gap.These frameworks emphasise human rights supported decision making traumainformed practice bodily autonomy self determination culture safety prevention violence abuse neglect exploitation.Severalspects of the proposedsome appear move awayfromthese principles towardmore restrictive standardised administratively driven systems.

Changes may increase expectations informal supports option includes a more vigorous consideration whatinformal support are reasonable delegates consider likely flow on impacts family members kin particularly younger people impact role informalsupport under Australia’sDisability Strategy1 Given most carers female theseimpactsmaybe disproportionately experienced bywomen. Changesalso potential affect certainClosingtheGapoutcomes 1 However implementation need carefullyconsider mitigate risedisproportionate impacts First Nations Culturally and Linguistically Diverse participants individuals who need with decisions or low literacy numeracy skills (SECURING THE NDIS FOR FUTURE GENERATIONS) BILL2026 EXPLANATORY MEMORANDUM

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

Submission 1418 TRELLIS MENTAL HEALTH

This submission will focus specifically on the impacts of the proposed legislation on women with disability and Aboriginal and Torres Strait Islander peoples in relation to Closing the Gap outcomes. I acknowledge that these reforms will also significantly impact men with disability; other submissions address broader implications across the community.

Impact of the proposed NDIS legislation on gender equality, safety and

the rights of women and girls

The Australian Government is committed global champion for Gender Equality under UNSCR Resolution:

We take seriously our commitment towards advancing Women’s Rights through UN SCR resolution. The second National Action Plan (NAP) aims at promoting gender equality, supporting resilience efforts across all genders while ensuring their full equal democratic participation within peace security frameworks.

National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026 Submission 1418 Trellis Mental Health

Supporting resilience, crisis, security law justice efforts

to meet needs rights all women girls demonstrating leadership accountability WPS.

Schedule Item Repeal section:

Removing participant-directed individualised planning reduces ability Women With Disabilty exercise choice Control supports participation parenting employment independent living For example one Autistic woman may requesting disability Supports access local book club whilst another Autistic Woman asking Access OT assist reducing overwhelm daily routines Under new legislation funding can assigned per impairment category autism rather than their Individual goals or Needs people disabilities fought Choice control over Funding because know what they need request government not remove from NDIS Another includes women with disabiltiy who choose engage female support workers intimate personal care such as showering due safety trauma cultural reasons under proposed legislative changes participants have reduced flexibility instead be required to access registered provider arrangements where limited no control gender Support Workers providing Intimate Care Choice providers decrease increased block funding blended payment approaches In my professional experience I worked many women psychosocial Disabilities experienced sexual violence perpetrated men would feel safe receiving intimate Personal care male support worker Reducing Participant choice and control these circumstances retraumatise Participants reduce service engagement create significant Safety risks This is small proportion for women Disability either of women with disability having Experienced sexual Violence since age 15 by Gender People with disability also Experience lack control Over Their personal safety Public hearing Preventing responding violence abuse neglect exploitation in disability services two case studies heard evidence residents had little Or no control Over their personal care provided it Following Sexual misconduct Life Without Barriers Worker towards Natalie resident group home her mother requested that Natalies personal care performed only Female Trauma already suffered Natalie Mother exacerbated Life Without Bars failure comply assurances put place Royal Commission into Violence Abuse Neglect Exploitation People With Disability report

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

Submission 1418

Schedule 4 – New Framework Planning:

Standardised budgeting and capped funding approaches may fail to account for the complex and gendered realities experienced by women with disability, including caring responsibilities, domestic violence recovery, trauma, parenting responsibilities and fluctuating support needs. Participants may lose choice regarding reasonable and necessary supports that meet their specific needs.

• Choice regarding where to live may be reduced if funding does not adequately reflect support needs.
• Choice regarding who to live with may also be reduced due to funding restrictions.
• Choice regarding assistive technology may be reduced despite assistive technology often reducing long-term support costs and increasing independence.
• Choice of providers may decrease due to increased block funding and blended payment approaches.
• Choice to obtain further assessments or challenge inaccurate assessments appears reduced.
• Access to capacity building interventions with allied health may be capped and not suit individual needs.

Schedule 1 - Proposed section 34A: Broad funding reduction powers may disproportionately impact women who rely on supports to safely parent children, escape violence, access employment or maintain community participation. In my professional experience, I have worked with many women with psychosocial disabilities, intellectual

disabilities and Autism who have experienced coercive control over their finances, significantly limiting their ability to independently access supports and services. Reductions to social and community participation funding, transport supports and other capped funding areas may disproportionately impact women in these circumstances, particularly where their individual safety risks and social circumstances are not adequately recognised within standardised budgeting models.I am not suggesting that the NDIS is responsible for addressing domestic violence itself.Rather, the NDIS plays an important role in funding the disability-related supports that enable women with disability to safely accesscommunity services, maintain social connection, attend appointments and participate in recovery and support

National Disability Insurance Scheme Amendment Bill

Introduction: Securing NDIS Future Generations

Submission Number:

Submission _[number]_

Document Title:

Trellis Mental Health - Violent Against People With Disabilities Factsheets

Section Heading:

pathways. Broad funding reductions or capping approaches which don’t consider individual situations increase isolation, dependence & vulnerability of disabled women facing coercion & violece. Rates experienced by these women are high as shown below:
\

[Image not converted to Markdown – check the source PDF page for the actual content] Types Of Emotional Abuse By A Partner (Since Age15): | Type Of Abuse | Percentage | |-| | Verbal abuse compared to without disability | 10% | | Constant humiliation and belittling, compared to without disabilitiy | 7% | Isolation from social networks comapred to without disability | 6 | Movements monitored compariedt o people with outdisability | 4 | Restricted access household finances compareo tpeople witout disablety | 3% source: Personal Safety Survey2016
Intimate partner violence since age $1$5 by impairment type: cognitive physical psychological sensoryand speech W M W M W M W M

National Disability Insurance Scheme Amendment Bill

Schedule 1 - Proposed Subsections 34(1G)-(1J)

Parenting and Family Responsibility:

The proposed amendments shift unrealistic caregiving responsibilities primarily on disabled women. This disproportionately affects them as they are often responsible caregivers, since over two-thirds (€67%) handle these roles without adequate support or limits set out regarding aging.

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

Submission 1418

“Due to the gendered nature of caring, women are more likely to be impacted by changes to the supports available or provided to the people they care for. 67.7 per cent of primary carers were women in 2022.” Changes are likely to increase informal caring responsibilities, which may impact levels of social and economic participation for female carers. Opportunities to increase gender equality will be considered as part of the design and evaluation of future market reforms to delivering social and community participation and capacity building activities.

           **(SECURING THE NDIS FOR FUTURE GENERATIONS) BILL 2026 EXPLANATORY MEMORANDUM**

Women carers who have increased caring responsibilities may be less able to participate in the workforce. In April employment figures there was an notable rise in unemployment among women’s numbers while many factors this also coincided with funding cuts to plans that already increased caregiving duties along decreased support worker other NDIS provider employment. Australian Unions concerned about a spike number jobless Australians shown today’s unemployment figures The rate rose up from March ABS labour force figures reveal More than jobs lost last month oil shocks began impacting business confidence Women took hit amid uncertainty climbing level not seen since mid-pandemic https://www.actu.org.au/media-release/jobless-rise-should-pause-any-more-interest-rate-rises/ Recommendation: Statistical analysis on rising women’s unemployment due reduced spending specific data collected on unemployment caused by caring responsibilities ndis jobs Schedule Proposed section (Alternative supports): Many excluded mainstream or informal supports exist despite experiencing poverty, isolation violence inadequate service access females severe profound disability receive government pension allowance main source income yet expected medicare services gap fees meet needs children Thriving kids proposals significant component allied health interventions accessed through medica prohibitive will result unmet need for women and their children People psychosocial disabilities told similar information If serious meeting needs outside of then increase number sessions fee Medicare rebates decrease size gap fee Better Access Chronic disease Eating Disorder Neurological Assessment Intervention items.

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

Submission 1418

Reducing sexual and gender-based violence

Women with disability experience significantly higher rates of domestic violence, coercive control, sexual violence and exploitation. Reductions in support access, independent living supports and safeguarding mechanisms can increase exposure to violence. Expanded reassessment powers can place individuals at increased risk during periods or instability due to their disabilities, such as psychosocial cognitive neurological conditions, communication barriers etc., leading them losing critical supports. The author has worked closely many women who are unable answer phones open emails letters due low energy mental illness executive functioning challenges associated these disabilities.

Schedule 2 – Fraud & Integrity Powers:

Expanding compliance investigative powers may create fear disengagement victim survivors particularly those suffering from psychosocial cognitive neurodisability history communications barrier already fearful making mistakes.

Schedule 3 - Automation Algorithmic Decision Making: Automated decision-making processes fail identify concerns risks vulnerabilities that require nuanced human assessment professional judgment existing tools appear disadvantageous women Life Skills Profile currently used assessments people psychosocial disability contains bias contributing lower rate accessing NDIS Women often present differently men relation psychosocial trauma responses masking which not adequately captured standardised assessment tools.

National Disability Insurance Scheme Amendment

Submission: Submission-1418 Trellis Mental Health logo

Similarly, autistic women and girls are frequently diagnosed later than males; their support needs often underestimated due to differences presentation social masking longstanding bias within diagnostic frameworks. Conditions such as Myalgic Encephalomyelitis/Chronic Fatigue Syndrome ME/CFS) diagnostic Long COVID disproportionately affect women minimised poorly understood resulting disability impacts underestimate. Developing automated decision-making or algorithms existing structural biases creates significant risk further entrench discrimination against women girls; systems without strong human oversight transparency gender-sensitive safeguards automation may amplify inequities reduce access appropriate supports. Artificial intelligence (AI) is transforming but when it reflects exiting biases can reinforce discrimination against womengirls From hiring decisions healthcare diagnoses AI systems can amplify inequalities trained biased data United Nations Women Assessment processes When functional capacity assessment need completed workers not allied health professionals they have reduced communication other skills notice red flags abuse including coercive control I reiterate point above regarding under recognised rated Funding to live in place choice 12 | Page

National Disability Insurance Scheme Amendment Bill

Submission 1418

Trellis Mental Health

Submission Text:

b. reform of NDIS participant funding models, such as Supported Independent Living (SIL), Specialist Disability Accommodation (SDA) & Individualized Living Options (ILOs). This should provide greater flexibility ensuring administrative pricing mechanisms do not favor group home living over other inclusive housing options.

c. Develop clear supportive transition pathways providing advice, advocacy support enabling people w/disability understand their choices in housing decisions receive necessary assistance during transitions.

This includes: • An individual assessment updating person’s needs preferences regularly, an updated NDIS plan including specific supports capacity building decision-making more independent living, a personalized transition plan identifying current available emerging alternative housing beyond provider offerings, independent advocacy and an independent coordinator facilitating these changes. Disability Royal Commission Final Report – Volume III: Nature extent violence abuse neglect exploitation

Supporting resilience crisis law justice responses for women girls Australia’s National Action Plan commits systems respond to all women girls rights The proposed legislation risks undermining this commitment for those with disability Schedule I Items - Permanence treatment Proposed permanence test undermines bodily autonomy informed consent creating pressure participants undertake treatments medical interventions maintain access disabilities There are broader concerns regarding gender inequity healthcare many medications historically less thoroughly tested on women Women pain side effects adverse reactions likely minimized dismissed within health care systems Historically experienced disproportionately high rates of coercion forced treatment loss body autonomy Will Women psychosocial disability chronic depression need ECT before accessing the NDIS How can they realistically achieve this? This Bill has a Too Bad So Sad feel rather than recognizing barriers faced by so many individuals with disabilities.

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

Submission 1418

The legislation should therefore explicitly protect the right of participants to refuse treatment without losing access to the NDIS.

The proposed provisions also fail to adequately recognise the impact of personal circumstances on a person’s ability to access treatment. Experiences of domestic and family violence, coercive control, caring responsibilities, poverty, housing instability and social disadvantage may significantly limit a person’s capacity to attend appointments, afford treatment, travel to specialists or safely engage with healthcare systems. Women are later to be diagnosed with many disabilities and therefore have a delay in being able to access treatments.

Despite this, proposed section 25A(2) specifically states that treatment may still be considered “appropriate reatment” regardless of whether a person’s individual circumstances restrict access to that treatment. This creates a serious risk that women experiencing violence, financial abuse or severe disadvantage may be unfairly penalised for circumstances outside their control.

“In general, people with disability, especially those with severe or profound disability, are more likely than peoplewithoutdisabilityto receivetheirincome mainly from agovernment pension,benefitor allowanceand lesslikely toreceive most incomefrom salaryowages.Ofpeople aged overwho havasourceofincom”: • governmentpensionoralloanceis themain sourceoffromforwithdisabilitypensionallowancetaxationgovernmentbenefit76% (or 13%) without disabiliycompared with 19 million)“,https://www.aihw.gov.au/reports/disability/people-with-disability-in-australia/contents/income-and-finance/income

Schedule 1 – ProposedsectionSustainabilityprinciples: positioningfinancialsustainabiltyasa dominantinterpretive principle risks deprioritisingsafety and human rights oftwomen girls with disability.This overrides participantrightsreasonableandsupportsthe economic modelling underpinning the proposed cuts reforms has not been transparently released.

Leadership accountability Australia’s National Action Plan emphasises leadershipaccountabilityconsultationaffected communities.The development implementation of this legislation raises concerns regarding whether women with disability have meaningfully included in decisionmaking. • Therehasinsufficient transparencyregardingthe longterm impactslegislationonwomentoysgirls withdisability.Aspreviouslynotedthegovernmenthassubmittedthat it willhavean inverseimpact on women. • Theresultsofgender impactanalysis,violencerisk analysisand safeguarding impact assessments. • Womenwithdisabilityparticularlypsychosocialintellectualautismneurological disabilitiesdoappear to havemeaninglyincludedinmanyaspects legislative

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

Submission 1418

treillis logo here

Design process: The two-week consultation period disproportionately affects women who are carers or disabled participants.

The lack of clarity regarding future rules reduces accountability; this prevents informed consultations due to unclear participant classes, budget methodologies, etc., impacting empowerment principles across multiple parts:

• Reduction/removal review processes/appeal rights;
• Complaint pathways removed/reduced; -Schedule I - Reassessments/Suspension powers may affect those with communication barriers, psychosocial disabilities, or fluctuating capacity negatively; Schedule II – Fraud & Integrity powers risk creating fear/surveillance/disproportionate enforcement impacts among people living with disability; Choice/control reduced throughout legislation; The proposed early intervention pathway might reduce long-term empowerment because it’s short term/potentially restrictive in structure; Legislation lacks sufficient support paths for individuals residing unsuitably/unsecurely transitioning into more suitable housing. Decreasing funding based on ‘classes’ supports can entrench ideas that some peoples’ abilities aren’t as important. Ministers decide whether all intellectual disabilities or FASD receive cut/capitalized funds without clear methodology and protections needed so the least able advocate themselves. Rationale not provided. Proposed legislation increases poverty/dependence/institutionalization/exposure violence against women/girls with disability inconsistent Australia’s commitments under National Action Plan Women Peace Security 2021–31 broader gender equality/bodily autonomy safety human rights recommendations Disability Royal Commission Closing Gap Labour election promises Comprehensive Gender Impact Assessment Violence Prevention assessment Disability Safeguarding should occur Care Support Workforce: women make up approximately of care/support workforce; $38 billion NDIS spending reduction over four years likely to have disproportionate significant impact.

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

Submission 1418 Trellis Mental Health

Employment Implications on Women Working Within Care and Support Workforce

Many women working within care support have their own caring responsibilities disabilities medical conditions which make it harder impossible transition into alternative employment scale speed proposed cuts could lead many seeking new jobs simultaneously increasing unemployment financial insecurity sector. Care support has created important opportunities culturally linguistically diverse CALD backgrounds including roles providing safe language-specific supports communities similarly Deaf people able gain meaningful employment supporting other deaf participants Reductions NDIS funding disproportionately impact these workers reducing access cultural appropriate accessible supports participants Concerning impacts disabled women who work with flexibility manage fatigue fluctuating health conditions disability-related needs caring responsibilities Some are limited very short shifts intermittent telehealth services flexible weekend hours childcare healthcare needs this level often not readily available industries extremely hard replace Sole trader allied professionals operate small businesses primarily because higher income but due flexibility allow them remain workforce managing disability, health conditions parenting or caregiving Significant reductions to ndis workforce may therefore force out of employment altogether Serious concerns regarding absence transitional funds business retraining assistance affected by reforms Many government-led structural changes accompanied large-scale disruption include financial packages pathways targeted employment No comparable transition appears offered despite significant scale proposed reductions Small businesses operating in the NDIS already reporting instability service reductions risks closure This includes sole traders multidisciplinary practices developed highly specialized expertise over years Allied health professionals valuable whose skills transferable across systems education rehabilitation mental community However sudden large-scale disruptions risk creating substantial unemployment and loss before sectors absorb these workers Approximately 25000 Australia’s Occupational Therapists estimated working within ndis sector Significantly reduced participant supports place proportion occupational therapy at high risk for unemployment underemployment business closure May also create long-term shortages lost disability that would be difficult rebuild future

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1418

Trellis Mental Health

Reforms that reduce the demand for NDIS services in the market will disproportionately affect women who make up approximately 68 per cent of the care and support workforce. Tightening the definition of reasonable and necessary supports will also reduce NDIS funding and demand for services across all support categories. Collectively, if reforms result in increased stress on provider viability, then governments may need to prevent market failure and ensure essential services continue.” (SECURING THE NDIS FOR FUTURE GENERATIONS) BILL 2026 EXPLAINTORY MEMORANDUM

First Peoples Community Fast Facts

• Of people aged redacted had a disability: 24%
• **Had profound or severe limitation:***12%
• Of those with disability (over redacted years old) had schooling restriction:*71%
• Reported experiencing at least one form abuse or neglect:`*20%

Australian Bureau Statistics & Avery S., (February. 25). Aboriginal Torres Strait Islander peoples with disability, Australian Bureau statistics.* [https://www.abs.gov.au/articles/aboriginal-and-torres-strait-islander-peoples-disability-2022](https://fpdn.org.au/ Changes have potential Closing Gap outcomes.“ However implementation needs carefully consider mitigate risk disproportionate impacts first nations Culturally Linguistically Diverse participants individuals who need support decisions low literacy numeracy skills.“ (SECURING THE NDIS FOR FUTURE GENERATIONS) BILL 2026 EXPLANATORY MEMORANDUM

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

Submission 1418

The Australian Government’s Commitment To Closing the Gap

The NDIS reform acknowledges potential impacts on various Closing the Gap outcomes. Australian government has committed itself towards these goals; legislation should not proceed where it risks worsening such results among First Nations people living with disabilities due lack of adequate analysis regarding its effects.

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

Submission 1418

For some First Nations participants, particularly those with psychosocial, neurological, intellectual or neurodevelopmental disability, the loss of support may result in rapid deterioration in both physical and mental health. Reduced access to disability support also has the potential to contribute to increased suicide risk and avoidable hospitalisation.

Participants living in remote and regional communities may be disproportionately impacted due to existing shortages of accessible health services and transport.

Children are born healthy and strong Target: By 2031, increase the proportion of Aboriginal and Torres Strait Islander babies with a healthy birthweight\nto (91percent).
Women with disability often require disability support in order to manage the determinants of healthy pregnancy outcomes, including:\n- attending antenatal appointments\n- taking medications consistently\ngrocery shopping and meal preparation\nmanaging fatigue and daily living tasks\ncaring for other children,includingchildrenwithdisability..If women lose disability supportsdue tounder stricter eligibility requirementsor reduced budgets,thismay negatively affect maternalhealth,stresslevels,nutritionandaccess to healthcare.Women witthpsychosocial disabilit,intellectualdisablety orcognitive impairments mays face particular barriersin proving they have completed all “reasonable treatment”requirements especially where there is trauma,homlessness,domestic violence,servicedisengagement or limited continuityof care.Suggested tracking:First Nationswomenwittdisability should betracked asaspecific subgroup within Closing th Gap reporting.## Children thrive in their early years and access culturally appropriateearly childhood educationTargets: By 2025,increasethe enrolment In Year Before Fulltime Schooling oo 95 per cent. By~~31, increase the proportion of children developmentally on track i nall five AEDC domains\nto (55per
cent.`

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

Submission 1418

Children’s Access to Education Services

Children with disability already experience significant barriers to participating in education and early intervention services. The proposed foundational supports model represents a substantial reduction in funding and intensity compared to current NDIS supports for many children. There are serious concerns that:

• children may lose access to intensive early intervention,
• therapy frequency will decrease,
• families will experience long waitlists,
• services will become more generic and less individualised,
• culturally safe and relationship-based supports will be replaced by short-term or fly-in-fly-out models., In many communities, allied health professionals embedded within the community have developed long- term trust and cultural understanding. Replacing these services with rotating NGO or contracted providers risks reducing continuity of care and cultural safety.

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

Submission 1418 Trellis Mental Health Students in remote communities may be disproportionately impacted due to limited alternative supports.

Suggested Tracking:

• First Nations children with disability
• children whose parents have disability
• developmental outcomes for children accessing foundational supports versus current NDIS supports.* Strong economic participation and development*

• Target:By 2031, *increase the proportion of Aboriginal and Torres Strait Islander people aged 25– -64 who are employed to $62%.**** Many First Nations people with disability rely on NDIS supports to participate in employment,* volunteering*, parenting and community life.*Reduced supports may lead to:*• loss of employment capacity• reduced access to transport• increased poverty• reduced ability to engage in training or education• increased reliance on unpaid carers• increased housing instability*.There is also concern that tighter price controls and reduced participant-directed funding may reduce opportunities for Aboriginal-owned disability support services and independent support workers operating within communities.The budget for social and community participation is being reduced by $50%, so the first nations people who are employed to do this work will either be unemployed,or their work rapidly cut in half.“Suggested tracking:• First Nations People With Disability### Housing securityTarget9a: By 2031, increase the proportion of aboriginal and torres strait islander people living in appropriately sized (not overcrowded)housingto$88%.9b:by 2031, all AboriginaLand TorreS StraiT IsLander households:”,“ | Page“: “21”

National Disability Insurance Scheme Amendment

Submission: Submission 1418

Within discrete communities receive essential services that meet or exceed relevant jurisdictional standard

within discrete Aboriginal and Torres Strait Islander communities receive essential services that meet or exceed the relevant jurisdictional standard in or near to a town receive essential services that meet or exceed the same standard as applies generally within the town (including if the household might be classified for other purposes as part of a discrete settlement such as “town camp”or “town based reserve”)

NDIS Supports often play critical role in helping people maintain housing through assistance daily living, emotion regulation transport budgeting cleaning attending appointments.

Loss of supports may contribute to:

• homelessness
• overcrowding inability sustain tenancies increased hospitalisation or incarceration. This is particularly concerning given existing overrepresentation of Aboriginal TorrestraitIslander people experiencinghousing insecurity.Suggested tracking: • First Nations People With disability Adults young are not Overrepresented criminal Justice systemTargetBy reduce rate of AboriginalTorresStrait Islaider Young people years detention at least per cent By reduce rate of AboriginalTorres StraiT islanders adults held Incarceration by Atleast per cent Many with psychosocial intellectual cognitive neurodevelopment disabilities rely on Disability supports Maintain safety stability community Reducing access increases contact police behavioural crises homelessness substance misuse incarceration risk For young people reduced early intervention family supports increase disengagement from school and youth justice systems.

Submission 1418

Suggested Tracking:

• First Nations people with disability Children are not overrepresented in the child protection system.

Target: By 2031,

reduce the rate of over-representation of Aboriginal and Torres Strait Islander children in out-of-home care by 45 per cent.. Parents with disability may require practical disability supports in order to safely care for children.. This can include:- support with routines,- transport,- meal preparation,- emotional regulation,- attending appointments,- home organisation. Removing or reducing these supports may increase child protection involvement despite the underlying issue being lack of support rather than lack of parental capacity.

Suggested tracking:

• First Nations children with disability*
• First Nations children whose parent/s have a disability* Families and households are safe.

Target:\By 2031,\the rate of all forms of family violence and abuse against Aboriginal and Torres Strait Islander women \and children is reduced at least by redacted%, as progress towards zero.capping participant budgets, using standardised funding models might fail to account for:domestic violence,cultural obligations,language barriers ,geographic isolation ,trauma histories,family complexity. # P a g e

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

Submission 1418

This may result in unsafe living situations where participants are forced to rely on unsafe family members or remain in violent environments because they cannot access sufficient support. Women with disability, particularly women with psychosocial or intellectual disability, may be disproportionately impacted.

Social and emotional wellbeing: Target: Significant and sustained reduction in suicide of Aboriginal and Torres Strait Islander people towards zero.The reforms may significantly affect social and emotional wellbeing for First Nations participants.Many participants rely on disability supports to:• Maintain community connection• Engage in cultural activities• Manage distress• Attend appointments• Prevent isolation• Access trauma-informed supportsThe uncertainty surrounding reassessment, treatment requirements and funding reductions may also increase distress and suicidality. The need for documentation to access the NDSI and maintain eligibility will have an increased burden on first nations people with more people not meeting this criteria due to the removal of geographical and low finances as considerations.An Aboriginal woman with psychosocial disability may avoid hospitals due to trauma associated with foster care homelessness or previous institutional experiences.She may miss appointments due to memory impairment emotion dysregulation executive functioning difficulties lack transport Under stricter treatment exhaustion requirements she may unable prove completed all recommended treatments therefore lose access ndis despite substantial functional impairment.Suggested tracking:* First Nations People With DisabilityPeople maintain a distinctive cultural spiritual physical economic relationship their land waters

National Disability Insurance Scheme Amendment

Submission: Securing the NDIs for Future Generations Bill 2026 - Submission No.:1418

Cultures and languages are strong supported flourishing

Target:

• Target A: By year 2030, there is an increase expected within Australia’s landmass subjecting Aboriginal & Torres Strait Islander peoples’ legal rights or interests.
• Target B: Similarly in areas covered under these people’s legal rights or interest regarding sea territories as well, By Year ‘2031’, there will be sustained growth of number strength spoken Indigenous Australian Languages being used widely. The cuts made on social participation would reduce access to lands, waters along with elders teaching culture and languages by approximately half (50%).

Currently participant-directed funding allows First Nations individuals choose support staff that understand community context; speak their native tongue; comprehend kinship structures; provide culturally safe assistance. More centralized service systems may decrease choice among participants while increasing reliance upon large NGOs without long-term ties into communities. This could potentially diminish cultural safety trust towards disability services provided.

Suggested tracking:

• First Nation People With Disabilities

Impact On CALD Participants And Families

However implementation must carefully consider mitigate disproportionate impacts faced by both First Nations or Culturally Linguistically Diverse (CALD) participants. Individuals needing decisional aid or having low literacy/numeracy skills are particularly vulnerable according to the SECURING THE NDIS FOR FUTURE GENERATIONS BILL 2026 EXPLANATORY MEMORANDUM text below: (SECURING THE NDIS FOR FUTURE GENERATIONS) BILL 2026 EXPLANATORY MEMORANDUM The proposed reforms might also disproportionately affect CALD participants families as well, currently allowing many CALD participants employ workers who speak their language.

• understand their culture and religion
• provide culturally appropriate meals and personal care
• support communication with family members and services
• understand trauma and migration experiences. More centralised or standardised service delivery models may shift supports toward large NGOs or agency-based staffing models where participants have significantly less control over who provides their care. This may reduce: • cultural safety • communication access • trust in services • participant autonomy • engagement with supports. For women from CALD communities, disability support work has also provided flexible and meaningful employment opportunities that align with caring responsibilities and language skills. Reductions in participant-directed funding and increased market centralisation may reduce employment opportunities for CALD women within the disability sector. This has the potential to negatively affect both economic participation and culturally appropriate care for participants.

Safety Concerns Regarding the Proposed Assessment Model There are multiple aspects of this legislation that raise significant safety concerns, including: needs assessments potentially being completed by unknown assessors lack of clarity regarding assessor qualifications and experience budgets being determined through standardised assessments without adequate review processes excessive pressure on participants to communicate all needs effectively during a single assessment

cultural, trauma-related and language needs potentially not be recognised within standardised funding modeslthe failure to assess the whole person ,including all disabilities and environmental factorsparticipants potentially being forced into unsafe living arrangements due to funding limitations.The assessment process must recognise that disability does not exist separately from environment,tamua,culture-language,poverty and safetystrong>Recommendations General Recommendations Do not pass the legislation in its current form.

• Delay implementation until the government releases full operational details regarding eligibility criteria,
• reassessment processes, assessment tools, participant classifications and funding methodologies.

• Undertake comprehensive and genuine consultation with people with disability, women with disability, Aboriginal and Torres Strait Islander organisations, CALD communities, allied health professionals and disability organisations.

• Extend consultation periods to allow meaningful participation by carers, women with disability, sole tradersandpeoplewithcomplexdisability.

• Publish transparent economic modelling explaining: o howparticipantnumberswillbereducedohowfundingreductionswerecalculated o projected impactsondisableoutcomes,helsealthcare systems,ClosetheGap outcomes,women’s outcomeshousingchildprotectionandeemployment. HumanRights,Safetyandsafeguarding Conducta comprehensivegender impactassessment disabilitysafeguardingassess mentviolencepreventionassesment Closingthe Gapimpact assessmen tCALDImpact assesse mntworkforceimpac tas ssest priortoimplementationofany reforms Ensureall reformsc onsistentwit h: • ther Disability Royal Commission recommendations • thenational PlanToEndViolenc eAgainstWomenAndChildren •thenation alActionPlan on WomenPeace AndSecurity 201–31 •Closing theG apcommitments Australia’sobligationsunderthec ommission of Persons WithDisabilities(CRP D). Maintainstronglegislative protectionsfor:bodilyautonomy

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

Submission 1418

• informed consent
• supported decision-making participant choice and control cultural safety trauma-informed practice. Explicitly protect the right of participants to refuse medical treatment without losing access to the NDIS. Ensure all reassessment, suspension and compliance processes include: -trauma-informed safeguards human review processes accessible communication methods protections for participants experiencing domestic violence, homelessness or psychosocial crisis.

Choice and Control Retain the principles currently contained in section 31 of the NDIS Act regarding: -individualised planning inclu ding consideration o f personal an d environmental circum stances participant-directed supports choiceandcontrol community participation flexibility Preventfundingmodelsfromassigningsupportssolelya ccordingtodiagnostic“classes”orimpairment categories Ensureparticipantsretainttherightto choose their support workers choic eculturallyappropriatean dgender-appropriatesupports chose where anda nd with whom they live acces s independent allied health assessments challenge inaccurateassessmentsanda ncfund ingdecisions Ensurfundingmodelsr e cogn individualcircumstancesincluding: •domesticviolence parentingresponsibilities trauma histories fluctuatingdisability

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

Submission 1418

• cultural obligations
• communication needs
• cognitive and executive functioning
• rural and remote living.

Assessment Processes

Ensure all functional capacity and support needs assessments are completed by appropriately qualified professionals with disability-specific expertise. Require assessors to have: • disable training cultural safety trainingtrauma-informed practice trainingunderstanding of psychosocial disability, autism, intellectual disability and neurological disability. Ensure assessment processes consider:the whole personmultiple disabilities and comorbiditiesenvironmental barrierssocial determinants of healthfluctuating capacitymasking and gendered presentations of disabilitie. Prohibit fully automated decision-making for eligibility,budgeting or reassessment decisions.Require transparent publication and independent review of all assessment tools and algorithms prior to implementation.Ensure participants can access independent review and appeal processes without unreasonable barriers.

Women and Gender-Based Violence

Ensure NDIS budgeting processes explicitly account fordomestic violence riskcoercive controlparenting responsibilities-traumarecovery-fluctuating support needs.Protect funding for supports that enable women with disability to:

• safely parent children • escape violence • maintain housing • participate in the community • attend healthcare and legal appointments.

Ensure women with disability can continue to request female support workers for intimate personal care where srequired for safety, trauma or cultural reasons.

Undertake further consultation with women with psychosocial disability, autistic women, women with to intellectual disability and women with chronic illness regarding assessment bias and access barriers. Review existing psychosocial disability assessment tools for gender bias and cultural bias.

Aboriginal and Torres Strait Islander Peoples

Understand direct consultation with Aboriginal Community Controlled Organisations and First Nations disabilityorganisations before implementing reforms. Ensure all NDIS assessment and planning processes are culturally safe and recognise:

• trauma racismhousing instabilityremote service access barriersekinship structureslanguage diversity. Ensure First Nations participants retain the ability to choose support workers and providers connected to theircommunities and cultures. Prevent replacement of communityembedded allied health servicesCollect and publicly report disability outcome data for Aboriginal and Torres Strait Islander people across Closingthe Gap targets.Provide additional tracking on closing the gap outcomes specific to disabilityReport on the impact of NDISreforms on these outcomes.Ensure no participant loses access to disability supports without appropriate alternative services already inplaceand independently evaluated.CALD Communities

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

Submission 1418 Trellis Mental Health

Protect participant choice to engage support workers who:

• speak their language
• understand their culture or religion
• provide culturally safe support.

Ensure reforms do not unintentionally reduce employment opportunities for:

• CALD women
• community-based disability workers.

Provide all assessment, review and compliance processes in accessible languages and formats. Ensure interpreters and culturally appropriate communication supports are funded and available.

Foundational Supports and Mainstream Services

do not remove NDIS supports until foundational supports are fully established, independently evaluated and adequately funded. publish detailed operational information regarding foundational supports before legislative changes commence. ensure foundational supports are: evidence-based;accessible;culturally safe;nuroaffirming; available in regional and remote communities. increase Medicare rebates and session limits for:Better AccessChronic Disease ManagementEating Disorder treatmentneurological and developmental allied health services.Reduce gap fees and improve affordability of allied health services outside the NDIS.

Workforce RecommendationsDevelop a comprehensive workforce transition strategy for the disability and allied health sectors.Provide:transition fundingbusiness supportraining pathways.

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

Submission 1418

• workforce retention strategies for providers and workers impacted by reforms. • Recognise the importance of flexible employment arrangements within the NDIS workforce for: o women with disability o carers o parents o people with chronic illness. • Undertake workforce modelling regarding the impact of reforms on:o Occupational Therapists o speech pathologists o physiotherapists o psychologists o support workers o rural and remote services. • Include Occupational Therapists and other allied health professionals in future policy and psychosocial early intervention design processes. • Ensure reforms do not create long-term loss of disability expertise from the Australian workforce.

Transition and Implementation

• Ensure no participant exits the NDIS without:a transition planconfirmed replacement supportscontinuity of caresafeguarding review where relevant.• Phase reforms gradually to prevent large-scale workforce disruption and service collapse.• Establish independent monitoring of:participant outcomesviolence riskshomelessnesshospitalisationincarcerationchild protection involvementvoluntary assisted dying rates in disabilitypage32

Submission 1418