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

By Chris Coombes

Dear Committee,

I’m Chris Coombes. I have previously held an appointment as an Independent Expert Reviewer for the National Disability Insurance Agency where I provided expert recommendations to NDIA participants whose complex matters were before Tribunals without resolution prolonged periods completing Masters in Human Rights Law Melbourne University masters Social Public Policy LSE makes me boring parties less so submissions

I’m nominee family member currently scheme person taught disability showy things above In spare time write grouchy articles about ndis train ndis providers Team DSC But this submission personal capacity because many you marched scheme deeply love care people daily use it changes saves lives believe can true scheme at once broken transformative now fear bill breaks further

ONE RECOMMENDATION This bill not pass Instead Minister urgently prioritise working disabled families Disabled Representative Carers Organisations providers community members humbly co-design plan deliver reform re-centres sustainable solutions truly align Convention on Rights People with Disability Royal Commission endorse Women With Disability Australia’s Submission echo calls

National Disability Insurance Scheme Amendment Bill

Submission: Submission-1569

similar rights-based intersectional impact assessments for this bill all instruments hereafter created including co-assessment rural remote First Nations communities And implore more time submissions exposure drafts Without which fear governments approach inconsistent with its requirements under United Nations Convention Rights Persons disability Arts , Restore Whole Person Approach Planning Amendments s34( aa ) omit arising from impairment insert directly impairments relates provision that must establish, support necessary address participants needs [directly] arises in relation to meets section or early intervention requirements see section my addition; directly into already unworkable S34(aa) will unintended consequences adds complexity scheme Participants report writers Delegates years review begged simplicity budget setting social policy however proposed provisions create dual experiences whereby access tailored information legal advice achieve decent supports outcomes borrow words: type inconsistency frequently arises when arbitrary tests may be deemed reasonable and necessary not applied costs every individual support rather whole based participant’s agreed needs This unnecessary layers decision-making within complex process reduces choice control breaking things down smallest level lost sight big picture person p ., Within-scheme inequities nit picking authors 0 Year Review original architects Scheme should bother widening gap now break exactly what (proposed test requires disabled people Example

National Disability Insurance Scheme Amendment Bill

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Dr Jennifer Haynes’ Case Study on Overnight Support Request

Meet Dr Jennifer Haynes, who last week survived an important Tribunal decision called “Haynes v CEO, National Disability Insurance Agency [2026] ARTA880” dated May 24th.

As someone deeply involved as both survivor advocate for sexual abuse survivors dissociating due to trauma, Dr Haynes has been advocating tirelessly within her field since she was a victim herself back when she had no name yet.

In addition to other modest supports provided under the scheme, Dr Haynes requested overnight assistance because they have many disabilities recognized through the NDIS system; however this request came at very late stage where it became necessary that she prove how these conditions meet criteria set out after reforms introduced during 2024 which require proving support needs arise from specific impairments listed according to ICF descriptors down into three-digit global codes and potentially even four digits if needed - something quite complex given current legislative schemes are trying hard to make things more complicated rather than simpler! The complexity of such requirements can be overwhelming especially those with intellectual or cognitive impairment issues like myself (First Nations participant) dealing fatigue in navigating systems while having few informal supports available. Thus far, the agency must identify exactly what disability(ies), based on planning stages, actually qualify them before moving forward towards determining whether said need arises directly off accepted impairments – an arduous task considering there were over fifty different ones identified by Dr Jennifer Haynes alone! This is often referred to as ‘quibbling’ but ultimately serves only to delay progress further still. Finally comes another challenge: identifying precisely which type(s)ofsupport required specifically stems from approved impairments within scope outlined previously. The Delegate has now been tasked with closing their eyes against interactions between various components involved under NDIS framework altogether.

Conclusion:

This case highlights significant challenges faced when applying for assistance through NDIS system due largely because of its overly bureaucratic nature compounded upon already existing complexities surrounding eligibility criteria interpretation.

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ineligible impairments and environmental impacts. Let’s not pretend it’s fair to send an APSSS to map mind-bodies’ entanglement—an epistemologically uncertain task from which even medical experts retreat.

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

Submission 1569

across multiple amendments, to moderate the powers seemingly at their fingertips, while their boss appears thirsty to show the Minister savings.

Example: Meshif met access to the NDIS 8 years ago. He’s now 70. He lives with complex needs across all domains arising from a spinal cord injury and mobilises using wheelchair. Eager to hit new KPIs, an NDIA Delegate points out s34(1)(g)’s provision about building him $0 plan because they believe his support is most appropriately funded through Aged care sector even though he still meets criteria under which people can be supported via NDIS. Despite assurances Meshif will manage okay without being solely dependent on NDIS due too many fraudsters within scheme, treatment: The proposed section 24(5), classification: Treatment clause of bill amendment, description: Defines when impairments are considered permanent or likely so unless certain conditions apply.

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threshold is much higher than the permanency threshold offered by Linda Reynolds. and LNP amendments aimed at removing less-need individuals from the scheme but commentators note it unintentionally removes those with substantially reduced functional capacity including permanent progressive conditions which won’t resolve without a panel established for analysis thresholds experts are assured we’ll establish. Example: Ayesha lives advanced Multiple Sclerosis bed-bound unable independently source or self-administer disease modifying therapies DMT’s corticosteroids MS impairment evidence-based treatments exist Australia treating team supply NDIA evidence even if she were able these as prescribed best case scenario will likely improve her ability minor activities like lift cup mouth remain bound But evidence lifting ‘noticeable improvement’ bureaucrat finds Despite Ayesha being in NDIS years Agency having details impairments advancing significantly since then revokes access because no longer meets permeance criteria Are hospitals aged care and foundational supports ready unethical cost-shifting exercise? Note this provision also impacts people who cannot participate treatment religious reasons seeking preserve bodily autonomy civil liberties electroconvulsive therapy have time explore extra requirements participants keep abreast new treatments lest removed I commend Justice Equity Centre initial submissions on question to Committee name chemical restraint cochlear implants absurd examples that transpire counter parliament stated intent Dr Monique Ryan told House 27th May sometimes access depends NDIS supports Reducing budgets: In (34(A)), reads, (1) For purposes ensuring financial sustainability National Disability Insurance Scheme Minister may by legislative instrument determine:

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(a) a percentage (lower than 100%) that is the percentage by which a funding component amount for a specified group of supports is reduced while the determination is in force; and The unbounded, unreviewable powers to reduce any budget by 99% places too much faith in future Ministers — think about your least favourite politician, and imagine what they could do with this power to the person you love. It is irresponsible and undemocratic to leave potentially billions of dollars in budget savings to one Minister. Worse still, this power does not solve the structural issues named in the ten-year review, which are driving up costs to the Scheme.Band aids on bullet wounds risk Scheme unsustainability political vulnerability legitimacy. Example: Tom’s civic and community participation budget is halved.Tom chooses to use remaining fundsfor intensive personal carewhile shopping fore groceriesattending appointments; his mates at pickleball work miss him.The ATO misses tax he’d pay ifonlyhecould getto work.Hismummisses retirement as she recommences informal labour.Most importantly,Tom misses independence.Ministerialpowers: Thereare no shortageof powersisted category D rules wheretheMinisterneed merely only ‘consult’withthestates.For example see34Apowerto limit plans below need-levels.As I heard MPs name their daughters SarahParker or young man who does shreddinginyour officeI felt nervous forwhat these cuts would mean forthier quality Of life.To add further concern,the bill invitesfurther incorporation by reference elevating into law documents like Pricing Arrangements Price limits even excel spreadsheets keptbyAgency –see 45C(11). MillsNational Disability Insurance Agency (NDIS) [2025] ARTA 1410 August 2025 captured absurd inconsistency relating te e-bikes permitted daily-changing FAQ page yet outlawed s ministerial instrument PAPL SDA Price Guides hold inconsistencies currently with the rule. This say

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nothing of the anti-democratic nature of these instruments. If I want to unelect or campaign against any minister(s) responsible for significant cuts affecting my plan—where they delete a line-item in either SDA Price Guide or PAPL critical to me—the CEO being beyond democratic reach, The enduring s10 lists from 2024 illustrate how powers created solely through ministers can create barriers leading costs upward. There’s no shortage here; many delegated rules proposed within this bill. Prime Minister concern about potential lawyer spend on Royal Commissions into Domestic Violence should not overshadow Agency spending millions on barristers over ‘standard items’ definitions—a day before operation without adequate community consultation. Proliferating more power allows unilateral scheme changes risks inconsistency and litigation. Parliamentary scrutiny is crucially important regarding efficiency legitimacy.

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endorse Sam Paior’s submission from the Growing Space and direct the Committee to her concerns. Participants deserve choice and control.

Example: Tom gets a plan at 16.He finishes school.as expected.This is not an unforeseen change so he is ineligible for a change of circumstance per the bill’s proposed threshold.His plan is insufficient for living a dignified post-school life – think work.living with flatmates.His plan.is renewed.He loses what would otherwise be the right to internally review the plan that.would have been built at his plan reassessment.(or end date). Thank you for reading.I would like my submission published on your webpage.with.my full name.At.the point.of submitting.there are ample incredible submissions.I encourage the Committee.to speak with as many people.who directly use the.Scheme as possible.and allow yourselves to.be moved.by their truth.For.this reason,I ask.not to participate in hearings.With love.appreciation.for all who.work hard to make this.Scheme better, Chris Coombes