NDIA Accountability Project

This project is in DRAFT

Community Options recommends that the Committee consider: (Provider advocacy)

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National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026 Submission 153

Community Options

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

Contacts: For more information, please contact: Brendan Taber, Chief Executive Officer

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

Submission 153

Table of Contents

  • Executive Summary … [Page Number]
  • About Community Options … [Page Number]
  • Increasing Demand evidenced by demand for our Access and Navigation Role … [Page Number]
  • Position Statement … [Page Number]
  • Concerns Regarding Proposed Eligibility and Functional Capacity Changes … [Page Number]
    • Real-World Example — Psychosocial Disability and System Navigation … [Page Number]
    • Exhaustion of Treatment Pathways Prior to Access … [Page Number]
      • Real-World Example – Delayed Intervention Escalating to Crisis …[Page Number] Impact on Hospital and Health Systems….[Page Number] Ageing Carers and “Sub-Threshold” Disability… .[Page Number]
      • Real-World Example—Carer Collapse Risk……..[Page Number] Cost Shifting to Community Organisations…………….…..[Page Number] Conclusion………………………………………..[Page Number] Recommendations………………….[Page Number] Community Options recommends that the Committee consider:…………..[Page Number]

Acknowledgement of Country

Community Options respectfully acknowledges the Ngunnawal and Ngambri peoples as the Traditional Custodians of the land on which the Australian Parliament stands. We pay our respects to their Elders past, present and emerging, and recognise their continuing connection to land, waters, and community. We also acknowledge and honour the contributions of all Aboriginal and Torres Strait Islander peoples to the life and culture of this nation.

Executive Summary

Community Options (ACT) acknowledges community and government concerns regarding the long-term sustainability of the National Disability Insurance Scheme (NDIS) and supports reforms aimed at ensuring the Scheme remains focused on Australians living with significant and permanent disability.

The organisation also recognises the importance of ensuring public funding is used effectively, consistently and sustainably into the future.

However, Community Options’ frontline operational experience indicates that several measures proposed within the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 may unintentionally increase exclusion and system instability for vulnerable individuals whose needs do not align neatly with revised eligibility and functional assessment frameworks.

Community Options is particularly concerned that tightening eligibility settings may occur ahead of the establishment of sufficiently funded foundational and transitional support systems across jurisdictions.

Through its self-funded Access and Navigation role, Community Options is increasingly supporting individuals who:

  • Experience significant functional vulnerability despite not meeting formal eligibility thresholds;
  • Experience psychosocial disability or fluctuating conditions;
  • Are unable to independently navigate assessment, reassessment and appeals processes;
  • Are ageing carers supporting adult children with disability;
  • Are discharged from hospital into unsupported or unsafe environments.

Operational experience indicates that many individuals excluded from formal systems nevertheless require substantial assistance to remain safely housed, engaged with healthcare systems and connected to community.

Drawing on its direct experience supporting people with disability, carers and families experiencing escalating complexity and service gaps, Community Options has seen firsthand how the absence of early navigation, stabilisation and transitional supports can lead to increased reliance on crisis-driven systems and services. Without these supports, Community Options is concerned that reforms aimed primarily at reducing NDIS growth may unintentionally increase pressure on: - Hospitals and emergency departments; - Housing and homelessness systems;
- Carers and families ; - Police and crisis responses;

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

Submission 153

About Community Options

Founded in 1989, Community Options is an Canberra based non-profit known for relationship-based case management, brokerage expertise, collaborative problem-solving.

  • Originally funded by Commonwealth Government to diversify care sector & shift towards personalized care enabling smaller community organizations participate service delivery through broker approach foundational model supported personalization allowing clients choose which providers perform tasks home. Over years as aged-care evolved collaborated ACT Health co-design implement range innovative programs responding emerging needs priorities including: Transitional Support, Flexible Family Support Community Assistance Program Women Newborn Community Support Palliative Care while also contributing to disability support schemes over many years due shifts within industry several programs essential addressing specific complex demographics gradually phased out by ACT Health Today focused on high impact where our approach adds most value active partners reform working government provider community design sustainable models deliver dignity continuity real-world outcomes.

Increasing Demand evidenced demand Access Navigation Role

Establish self-funded role response growing numbers vulnerable individuals presenting significant unmet support despite not qualifying or being unable successfully engage formal systems regularly supports experiencing psychosocial impairment aging carer arrangements housing instability hoarding and neglect concerns;

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

Submission 153

‘community options’

  • hospital dischage complexit;
  • barriers engagin with th NDIS agd cae nd healh systms.

Community Optons hs obsved incr sing prsnttions fr indivds whr n “unwell enou” t qualif or acut crsis sys ts bt rlsbl nd abl tnld mntain sfe sdstble cmnty lving wthout ngng suprt nd navgt assstnc. In mn cses, individuls rqur substnl ssstnc: • complte foms nd asssmnts; • ttnd appontmtns; • navigat ppals pcssns; • coordint hsg nd hlthcr sppts; • mtntn tenncy stbllty; • gnrg apprpttlly wrv svcs. Wlshse sssts rn offn ll-cost d pnvtntiv nt,n thr absnce nf tmly tenvnent fnqrlts to escslg csis, incrsed cmpxity nd grtr rlcn on emrgcy and acut svc sy sn. Communti Opnts consdr the gwrng dmmd for this unfundrd svce b a signfcnt indcrrorf brderr systcm flr,r, wih icrcsing gp nd ftmmtgr frmg rng ccross th ddscrbility,hlt, hgsing and agd cr sys ts.Over rcent yr,s Communit Optons hs obsvd incr sing prsns nvolving pschsocl cmplcty,,agig carr arrgnmn,t hhg instblty nd indivds unbl t nnldny navgt formls ystms dp sftnc funcnl vulnrbrty.Dmnd fr assstnc nd suprt fm our Accss nd Nvgtn rol h cninu td cnsre throughout hr 205/6 financyl rr,y pcrllry rtlnngto: • NDIS accs nd reasssmmnt procrss; • pschosocl dability;hspitals dcshage cdnnltd;ngh stbllty;cumulv ssym complcxit.This trnd hlglts grwng prsr on commnut orgnztons to sptr individuls wh do nt mt fnml lgbilth thrsholds bt nrve slbsrl intvrvtion nd suppfr tp vnt csis escsl.

Community Options National Disability Insurance Scheme Amendment (Securing the NDIS for future generations) Bill 2026

Position Statement

Community Options supports reforms aimed at improving the long-term sustainability, integrity and consistency of the National Disability Insurance Scheme (NDIS).

However, Community Options’ frontline operational experience indicates that some proposed reforms may unintentionally increase exclusion for individuals whose disability impacts are cumulative, fluctuating or difficult to quantify within standardised assessment frameworks.

The organisation is particularly concerned regarding:

  • Increased reliance on standardized functional assessments;
  • Approaches requiring exhaustion of treatment pathways prior to access;
  • Uncertainty regarding foundational support systems for individuals excluded from the NDIS;
  • Growing pressure being transferred onto health, housing, carers and community organisations.

Through its self-funded Access and Navigation role, Community Options is increasingly supporting individuals who:

  • Have been deemed ineligible for the NDIS despite significant functional vulnerability;
  • Are unable to independently navigate reassessment, review or appeals processes;
  • Experience psychosocial disability, trauma-related impairment or cognitive decline not easily evidenced through formal assessment;
  • Awaiting reassessment or plan review outcomes for extended periods;
  • Being discharged from hospital into unsupported environments. Our operational experience suggests that where individuals are unable to access appropriate supports early presentations frequently escalate into crisis responses involving hospitals emergency departments homelessness systems police acute carer breakdown.
    Community Options believes sustainable reform of the NDIS must occur alongside targeted investment in foundationa lcommunity suppor ts navigation services transitional pathwa ys Concerns Regarding Proposed Eligibility and Functional Capacity Changes
    Community Options concerns proposed tightening eligibility requirements increased reliance function capacity assessmen may disadvantage individu als whose disabilit impacts fluctuating difficult capture within standardised asse ssment frameworks Through its Acces nd

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

Submission 153

Community Options regularly supports individuals experiencing significant functional impairment who nonetheless struggle to meet formal evidentiary thresholds. Our frontline experience indicates that standardized assessments do not always adequately capture the cumulative impact of psychosocial disability, trauma-related impairment, executive functioning difficulties and complex social instability. As a result, some individuals may appear functionally capable during isolated assessments while remaining unable to sustainably manage housing, healthcare, finances, appointments or community participation without substantial external support.

Real-World Example — Psychosocial Disability and System Navigation

Community Options recently supported a middle-aged individual experiencing chronic psychosocial disability, a significant trauma history, executive functioning impairment and housing instability.The individual was able to present relatively well during short clinical interactions; however:

  • Was unable to independently complete forms or attend appointments consistently;
  • Repeatedly disengaged from services due to overwhelm;
  • Accumulated tenancy breaches;
  • Experienced significant self-neglect;
  • Presented to emergency departments during periods of crisis. The individual did not meet thresholds for sustained community support through multiple systems and instead cycled between crisis presentations, short-term interventions and disengagement.From Community Options’ perspective, the issue was not absence of need, but rather the inabilityof existing assessment frameworks to adequatey capture cummulative functional vulnerability.Community Options is concerned about increased reliance on standardised functional assessments which may further exclude individuals with fluctuating psychosocial conditions who do not present consistentltyduring formal assesssments.

Exhaustion of Treatment Pathways Prior To Access

Community Options concerns that proposal requiring individulas exhaust treatment options prior access supports.In practice many vulnerable indivduals experience substantial barriers accessing treatement pathways in first instance including:*

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

Submission 153

Real-World Example — Delayed Intervention Escalating to Crisis

Community Options supported an older carer caring for an adult son with suspected intellectual disability and significant mental health concerns. The family had attempted for several years to engage multiple systems including: • public mental health; • housing services; • disability assessment pathways; • NDIS access processes.The individual repeatedly disengaged from services and struggled to tolerate formal assessment processesDuring this period:the ageing parent’s health deteriorated significantly;police attended multiple welfare concerns;the tenancy became unsafe due to hoarding and self-neglect:both individuals became increasingly socially isolated.By the time intensive intervention occurred, both the complexity of the situation and the level of multi-system involvement required had escalated significantly and were far greater than may have been necessaryhad earlier navigation, engagement and stabilisation supports been available.Community Options is concerned that requiring prolonged treatment exhaustion prior to eligibility mayincrease crisis escalation for highly vulnerable individuals.

Impact on Hospital and Health Systems

Community Options is increasingly observing individuals remaining within hospital settings not because ofacute medical need, because safe and sustainable discharge pathways do not exist.

Operational Experience

Operational experience indicates that discharge delays are frequently linked to:

  • lack of disability supports;
  • housing unsuitability;
  • absence of carers or informal supports;
  • delayed NDIS reassessment processes;
  • inability to independently coordinate services;
  • psychosocial instability and executive functioning impairment. Within the ACT, Community Options has also observed increasing pressure on community organisations and health systems as vulnerable individuals experience difficulty navigating fragmented systems across disability, mental health, housing and ageing sectors.

Real-World Example — Functional Need Without Appropriate Supports

Community Options recently assisted an individual discharged from hospital following significant health deterioration. Although the individual demonstrated substantial functional limitations affecting daily living, discharge was considered unlikely to remain sustainable without timely access to formal disability supports.

Operational Experience

Operational experience consistently demonstrates that relatively low-cost early intervention, navigation and stabilisation supports are significantly more effective and cost-efficient than prolonged crisis responses once individuals have deteriorated.

Ageing Carers and “Sub-Threshold” Disability

Community Options is seeing a growing number of ageing parents and carers supporting adult children with disability whose support needs remain largely unmet because they either: • do not meet revised NDIS thresholds; • have never successfully navigated the application process; • have psychosocial or cognitive impairments without formal diagnosis; • experience fluctuating functioning. These carers are increasingly ageing without long-term support plans in place.

Real-World Example — Carer Collapse Risk

Community Options recently supported an elderly parent caring for an adult child with severe anxiety, suspected autism spectrum disorder and functional dependence. While the adult child could complete some daily tasks independently, they were unable to: • manage finances; • engage with services; • maintain employment; • independently navigate healthcare systems; • sustain social or community participation.The parent expressed significant fear regarding: • what would occur upon their death; inability to continue caring responsibilities; lack of appropriate service pathways. Community Options notes that many individuals within this cohort may not meet increasingl y narrow disability thresholds despite requiring substantial long-term support to remain safely housed and connectedto community.

Cost Shifting to Community Organisations

Community Options currently self-funds its Access and Navigation role in response to increasing numbers of vulnerable individuals presenting outside formal funded systems despite requiring substantial support and intervention to safely remain living and connected in the community.

Operational demand within the role highlights increasing fragmentation and service gaps across the disability, health, housing, psychosocial and aged care systems, particularly for individuals with complex and overlapping support needs. The organization is increasingly providing unfunded support relating to:

  • Service coordination;
  • Advocacy;
  • Housing navigation;
  • NDIS guidance;
  • Psychosocial stabilisation;
  • Crisis prevention;
  • Hospital discharge coordination.

Community Options is concerned that without significant investment in foundational and transitional supports, community organizations will continue absorbing increasing levels of complex unfunded demand as individualsthat are excluded from formal systems, creating an unsustainable burden on already stretchedcommunity services and workforces. This approach risks shifting costs away from the NDIS while increasing pressure on hospitals,housingsystems, carers, police, crisis services and underfunded community organisations.

Conclusion

Community Options supports the long-term sustainability and integrity of the National Disability Insurance Scheme and acknowledges the importance of ensuring public funding is used effectively. However, frontline operational experience indicates that many vulnerable individuals already experiencessubstantial barriers navigating disability, health, housing and aged care systems despite significanfunctional impairment and social vulnerability.The organisation is increasingly observing individuals who fall outside formal eligibility frameworks butnevertheless require substantial support to remain safely housed, connected to healthcare systemsand engaged with community. — PAGE TEXT END –

Community Options

Submission 153

Recommendations

  • Ensure revised eligibility frameworks appropriately recognise psychosocial, fluctuating and cumulative disability impacts;
  • Ensure functional capacity assessments consider real-world functioning over time rather than isolated assessment presentation;
  • Remove treatment exhaustion requirements which are likely to create unreasonable challenges and barriers for individuals unable to independently navigate complex fragmented service systems;
  • Establish a nationally funded foundational Navigation and Transition Support Stream for individuals unable to access or sustain engagement with the NDIS;
  • Undertake detailed modelling regarding likely cost-shifting impacts onto:
    • Hospitals and emergency departments.
    • Housing and homelessness systems,
    • Carers and families;
    • Community sector organizations ;
  • Establish stronger transition pathways and early intervention supports for individuals found ineligible for the NDIS;
  • Increase investment in community-based psychosocial navigation stabilisation support aimed at reducing crisis escalation avoidable hospital presentations;
  • Consult directly frontline organisations experiencing increasing presentations from individuals falling between disability health housing aged care systems.