Submission 156
Level 5, Tower B, The Zenith, 821 Pacific Highway Chatswood NSW 2067 aspect Autism Spectrum Australia 1800 277 328 customerservice@aspect.org.au www.aspect.org.au ABN 12 000 637 267
Introduction
Autism Spectrum Australia (Aspect) welcomes the opportunity to provide a submission in response to the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 (referred in this submission as “The Bill”)。
Aspect is one of Australia’s leading autism-specific service providers, with 60 years’ experience supporting Autistic individuals and their families across their lifespan. We deliver education, allied health, behaviour support, and community-based services, underpinned by research through the Aspect Research Centre for Autism Practice (ARCAP).
Our submission focuses on the implications of the proposed amendments for Autistic people, their families, and the broader disability ecosystem.
Overview of key concerns
Aspect acknowledges the Government’s objective to ensure the long-term sustainability of the NDIS. Aspect also raises that several proposed measures risk unintended consequences specifically for Autistic participants that may reduce access to essential supports, increase inequity, and shift costs to families and other service systems which do not have the infrastructures or resources to provide best practice supports.
Key areas of concern include:
- Child safety, vulnerable person safeguarding and participation
- Functional capacity definition
- Access and permanence criteria
- Link between impairment and supports
- Value for money and evidence hierarchy
- Funding caps and reductions
- Plan reassessments, flexibility and automatic plan renewals
- Increased family responsibility and Administrative Burden
- Shift to “foundational supports”
- Workforce system and sustainability
Submission 156
1. Child safety, vulnerable person safeguarding and participation
Aspect emphasises that child safety and vulnerable person safeguarding must be explicitly embedded across reforms. A major protective factor in safeguarding is when children and vulnerable people are included within the community with appropriate supports. This ensures increased oversight and safeguarding, minimising isolation as a significant risk of abuse and neglect. Funding reductions for those with complex support needs places children and vulnerable people with disability at significant risk of harm.
Recommendations
The Bill should consider community participation and engagement as an important safeguard against abuse and neglect of children and vulnerable people with disability, carefully balancing sustainability of the NDIS with the safety and wellbeing of the disability community.
2. Functional capacity definition
The Bill defines functional capacity as a person’s ability without assistance and excluding environmental context. This approach does not reflect the lived reality of Autistic people, whose functioning is: o Highly context-dependent (e.g. sensory environments, routines) o Often support-dependent (e.g. assistive technology, scaffolding) o Subject to fluctuation over time
Recommendations
Functional capacity must be assessed in real-world contexts, including supports and environments. Policy should also recognise dynamic and situational capacity, not static impairment.
3. Access and permanence criteria
The Bill introduces a requirement that impairments are not considered permanent unless all “appropriate treatment” has been undertaken. Autism should not be framed as “treatable“ - it is a lifelong and permanent disability, and therapies should not be interpreted as “curative”.
Recommendations
Autism should be explicitly recognised as a permanent, lifelong disability. Safeguards are required to prevent misuse of the “appropriate treatment” clause. Access should therefore not be conditional on exhausting all therapies with the aim to “cure” or “fix” the disability.
4. Link between impairment and supports
The Bill strengthens the requirement that supports must arise directly from an impairment. Autism supports are often:
- Guided by neurodiverse-affirming early intervention and therapeutic approaches.
- Capacity-building
- Participation-oriented and inclusive, including the participant’s voice and choice in supports.
If supports are interpreted narrowly there is the risk that they will not be approved or supported under the proposed Bill.
Submission 156
Recommendations
Recognise that effective autism supports include early intervention and therapeutic supports that are strengths-based, capacity-building and result in social and participation outcomes, avoiding a purely deficit-based funding model.
5. Value for money and evidence hierarchy
The Bill prioritises peer-reviewed and generalisable research when determining effectiveness. This may lead to a disadvantage of personalised and emerging supports. This may also exclude neurodiversity-affirming practices which lack large-scale trials but demonstrate ethical and effective supports for Autistic people. This also limits innovation and individualised care approaches which can be important particularly when supporting complex care.
Recommendations
Adopt a broader evidence framework that includes:
- Lived experience
- Individual outcomes
- Practice-based evidence
- Neurodiversity-affirming approaches.
6. Funding caps and reductions
The Bill enables the Minister to reduce funding across groups of supports and set maximum levels. This could mean reduced therapy, behaviour support and core support hours. This will lead to further increased unmet needs across the disability community and disproportionately impact people with complex needs. Implementation of funding reductions on an individual level can affect wellbeing and increase behaviours of concern, resulting in additional and further need for intensive supports overtime, or increase pressure on other government agencies such as health and education.
Recommendations
Introduce transparency in funding decisions and have safeguards in place to protect high-support participants with complex needs who will be significantly impacted by funding restrictions. The Bill should strengthen review and appeal mechanisms, ensuring that the most vulnerable and complex participants are able to voice their views and access appeals fairly.
7. Plan reassessments, flexibility and automatic plan renewals
Reassessments are restricted to significant and ongoing changes. They fail to reflect episodic changes such as:
- Transitions (school, adulthood, moving out of home)
- Burnout, regression and decline due to mental and physical health conditions.
This delay in necessary plan adjustments may increase the likelihood that more intensive supports will be required. In addition, if plans are automatically renewed without full reassessment, there is the risk of reduced participant voice and co-design, outdated supports continuing and missed opportunities to adjust support to changing needs.
Recommendations
Reassessments should be enabled for:
- Life transitions
- Environmental, physical, and mental health changes
- Fluctuating needs
- Guaranteeing participant involvement in renewals
Submission 156
- Establishing clear review trigger points.
- Increased family responsibility and administrative burden The Bill reinforces expectations that families provide substantial care and support. This results in increased caregiver burden, risk of burnout and reduced workforce participation and blurring of disability supports and parenting. Expanded compliance, evidence and reporting requirements are being introduced in the Bill which increases complexity for participants and families, disproportionately impacts Autistic people with executive functioning challenges and creates a greater reliance on informal advocacy. This in turn risks family and caregiver burnout.
Recommendations
- Clearly distinguish disability-related support from parental responsibility
- Recognise and support care, sustainability, and wellbeing
- Simplify processes and provide accessible communication adjustments
- Fund navigation and advocacy support.
- Shift to “foundational supports” Supports may be excluded if deemed more appropriate for other systems, such as foundational supports. There is the risk of service gaps and cost shifting to underfunded systems (e.g. health, education).
Recommendations
- Ensure foundational systems are fully funded and operational first
- Introducing accountability mechanisms across systems
- Guarantee no participant is left without support
- Provide planning support for those who may exit the scheme to ensure they understand and are able to access alternative support.
- Workforce and system sustainability The reforms occur in a context of workforce instability and service demand pressures.
Recommendations
- Develop a national NDIS workforce strategy
- Recognise and fund the high responsibility and training costs incurred by large NGOs to build and sustain the workforce, particularly for those organisations that support complexity.
Autism Spectrum Australia