Submission 1536

Dear members of the Australian Government,

I write this as a concerned Occupational Therapist working within the NDS sector. While I acknowledge the perceived bias relating to my employment, my primary fear is for my clients and the community of NDIS participants who rely on the NDIS for safety, dignity, and quality of life.

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

The planned changes appear to recreate conditions associated with institutionalisation: people with disability being segregated from community life, grouped together in unsuitable settings, and supported under unsafe staffing ratios that fail to meet complex needs.

These Government decisions risk devaluing Australians living with disabilities they never chose to have.

Defining “Permanent Disability” and “Appropriate Treatment”

People should not have to prove they have exhausted every possible treatment pathway simply because they cannot afford or access them. The proposed definitions create a significant equity gap. Eligibility risks becoming dependent on a person’s ability to access and exhaust all treatments deemed “appropriate” by the NDIA before applying. This disproportionately disadvantages people experiencing financial hardship, regional barriers, long waitlists, or limited specialist access. These are solutions to ‘fix’ the NDS budget, however it shifts the burden back onto families, health systems, crisis services, and state / territory services no longer active. These changes are effectively returning Australia to conditions that existed prior to the NDIS.

Reliance on Research and Peer-Reviewed Evidence

Will all decision makers have the skills distinguish between high-quality clinical evidence, emerging practice evidence, and unreliable information sources? Will they be clinically qualified to decide what is acceptable and best practice for EACH disability? The proposed emphasis on research and peer-reviewed evidence raises significant questions about how evidence will be interpreted by the NDIA and applied to decision-making. For example, Applied Behaviour Analysis (ABA) therapy is not best practice but has previously been strongly advocated for by politicians. When there is no evidence, how will supports be provided? If formal research evidence is limited, what evidence framework will be used to ensure participants with, for example, complex behavioural needs receive appropriate supports?

Submission 1536

“Reasonable and Necessary” supports and removal of “Same Outcome“ The NDIS should NOT adopt a “she’ll be right” approach which will prioritise cost over participant safety, dignity, and quality of life. The removal of wording “same outcome” participants will only receive the lowest-cost option, rather than the safest and most clinically appropriate solution. For example, a participant may technically “get by” with a basic off-the-shelf wheelchair. But, prolonged use will likely significantly reduce the persons function and independence, while creating serious safety risks for those who support them. A customised wheelchair is often the most suitable seating system for some of my clients; they cost significantly more however they improve quality of already disabled life and improve function. Without scripted features disability needs increase and quality of life worsens.

Deferring to Informal Supports and Removal of Support Coordination When adequate formal supports are unavailable, families are pushed to crisis point, this has a direct impact on Australian society. Families, most often mothers, are being expected to provide complex coordination, advocacy, and direct care far beyond the role of reasonable family expectation. Overreliance on informal supports is one of the leading contributors to carer burnout, family breakdown, and long-term system failure. The removal or reduction of Support Coordination places unrealistic responsibility onto participants and their informal support networks to navigate an increasingly complex system independently. Phone calls are currently being made to participants who don’t have the capacity to represent themselves in a system that has already made decisions about their disability support requirements. Support Coordination is not an optional extra for many participants, it is their point-of-contact that allows the rest of the plan to function effectively.

Reduction in Social and Economic Participation Funding Blanket reductions to social and economic participation funding risks creating severe isolation for people with disability while simply shifting costs elsewhere across government systems. Limiting community access and participation does not reduce need, it creates isolation for those already disadvantaged. Social and community participation is not a luxury. It is fundamental to inclusion, wellbeing, self-management, and human dignity.

Suggestions:

• Review internal NDIA processes to improve communication between systems and reduce ongoing inefficiencies, duplication, and administrative delays.
• Strengthen internal NDIA financial and plan management systems to reduce opportunities for provider fraud.

• Submission 1536

• Fraudulent practices are regularly observed across the sector for various sums; this is an internal systemic weakness not a participant issue.

• Ensure all participants are clearly informed of their recognised NDIS disability/ies so participants and support teams understand their scope of practice.

• Review the use of vague diagnostic categories such as “other physical condition”, these provide no clarity for participants or providers.

• Implement a clinical review pathway whereby eligibility assessments and participants ongoing reports are reviewed by appropriately qualified AHPRA- registered clinicians to support consistent planning decisions and access to reasonable therapeutic supports.

• The Department of Veterans’ Affairs (DVA) model provides an example of peer-reviewed clinical assessment processes that are concise, relevant, and professionally informed.