National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1572
Re: Concerns Regarding the NDIS Bill and Its Impact on Early Intervention, Plan Flexibility, and Long-Term Scheme Costs
Dear Minister Butler and Senator McAllister
I would like the opportunity to raise concerns regarding the proposed NDIS Bill.
This statement outlines how several elements of the Bill risk increasing long-term NDIS costs, reducing access to early intervention, and locking children with emerging needs into inflexible plans.
My perspective is informed both by my lived experience as the parent of a newly-accepted NDIS participant, and by my clinical background, holding a Graduate Diploma in Mental Health and Neuroscience, which gives me a clear understanding of the predictable and preventable consequences of delayed diagnosis and delayed access to supports.
- The NDIS’s largest costs do not come from children or early intervention
Government data shows the highest-cost areas of the NDIS are:
• Supported Independent Living (SIL) costs approximately $11B/year, supporting only around 6% of participants
• Specialist Disability Accommodation (SDA), approximately $2.5B/year
• High-intensity supports cost approximately $1.5B/year
Combined, these categories represent over $15B, nearly 40% of the entire scheme.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1572
In contrast:
• Early intervention plans typically cost $10K–$20K/year
• Children with developmental delay make up 48% of new entrants, but only 12% of total scheme costs
• Early intervention is not a cost driver, it is a cost-prevention means.
- Administrative inefficiency is a major cost driver, yet the Bill does not address it
NDIA operational costs are approximately $2.4B/year, including:
• legal and Tribunal costs
• internal reviews
• external contractors
• duplicated assessments
• automated decision systems
• staffing and overhead
The Tribunal backlog alone has cost $720M/year.
The NDIS Review (2023) found that 30–40% of NDIA decisions are incorrect or poorly reasoned, creating unnecessary churn, appeals, and re-planning.
The Bill does not address these inefficiencies. Instead, it expands the NDIA’s administrative powers.
- Delayed diagnosis and delayed access increase long-term costs: April’s case
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1572
My daughter April’s timeline demonstrates how system delays escalate needs and costs:
• At 8 years old she received her ADHD diagnosis.
• We were then delayed another 3.5 years before an autism assessment
• It was around another year before she was able to access the NDIS.
• Now likely another 12 months before appropriate supports are funded
April received no early intervention, not because I didn’t ask for any, but because:
• assessments for autism have very long waitlists
• NDIS require an autism diagnosis and routinely reject applications relating to ADHD functional impairments
• This meant that the system required escalation of behaviours, before providing support.
As a result, April now requires:
• Positive Behaviour Support
• Occupational Therapy
• Psychology
• Speech Pathology
• Specialist Support Coordination
• Support workers
Her full plan cost is now likely to be upwards of $120K per year
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1572
If early intervention had been available at age 8, her supports would likely have cost $10K–$20K/year, and her current needs would be significantly lower.
- Early intervention reduces long-term NDIS costs
The NDIS Review (2023) found that early intervention:
• reduces behavioural escalation
• reduces school refusal
• Reduces acute mental health presentations
• reduces family breakdown
• reduces the need for restrictive practices
• reduces the need for 1:1 support
• reduces the likelihood of entering SIL
The Review concluded:
• Early intervention produces the largest lifetime savings and the highest return on investment.
Cutting early intervention does not save money it shifts costs into adulthood, where they are exponentially higher.
- Long plan terms for new participants with emerging needs increase risk and cost
The NDIA’s own guidelines state that long plan terms are appropriate only when:
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1572
• needs are stable
• supports are established
• no major changes are expected
April is a new participant with:
• emerging needs
• escalating behaviours
• no established therapy team
• no behaviour support
• no support workers
• no environmental supports
• no early intervention history
A long plan term is clinically unsafe and economically irrational.
If the Bill passes, long plan terms will become harder to change due to:
• category caps
• automated decision-making
• reduced review rights
• increased administrative discretion
Locking a child like April into a long plan term under these conditions risks:
• underfunding
• escalation
• crisis intervention
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1572
• long-term high-cost supports
This is the opposite of sustainability.
- The Bill risks putting more families in the same position as ours
By restricting early intervention and increasing administrative barriers, the Bill will:
• delay access
• reduce therapy
• reduce behaviour support
• reduce community participation
• increase school refusal
• increase behavioural escalation
• increase family stress
• increase crisis presentations
• increase long-term NDIS costs
Children who miss early intervention are far more likely to require:
• high-intensity supports
• 1:1 staffing
• out-of-home care
• SIL as adults
SIL costs $350K–$500K/year. Early intervention costs $10K–$20K/year.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1572
The economic logic is clear.
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Recommendations
-
Protect early intervention funding
Early intervention is the only evidence-based process that reduces long-term NDIS costs.
- Prohibit long plan terms for new participants with emerging needs
This prevents children from being locked into inappropriate plans under new rules.
- Address administrative inefficiencies
Improve decision quality, reduce churn, and reduce reliance on appeals.
- Prevent category caps that restrict therapy and behaviour support
These supports reduce long-term costs by preventing escalation.
- Strengthen pathways for ADHD-related functional impairment
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1572
This would have allowed April to receive early supports at age 8.
Conclusion
As a parent and as professional I am deeply concerned that the Bill, as drafted, risks increasing long-term NDIS costs by:
• reducing early intervention
• increasing delays
• locking children into inflexible plans
• expanding administrative powers
• failing to address the true cost drivers
April’s case demonstrates the predictable outcome of delayed diagnosis and delayed access: higher needs, higher risk, and higher long-term cost.
A sustainable NDIS requires:
• early intervention
• flexible plan terms
• high-quality decision-making
• reduced administrative churn
• recognition of ADHD-related functional impairments
Not reductions in therapy, behaviour support, or early intervention.
Thank you for your consideration.