Final Submission

Integrity must include safety, choice and control, and real support beyond the NDIS.

Prepared by Founder Capacity Organisational submission / public briefing paper Status Draft - may be submitted as a late submission or used as a public advocacy briefing Date July 2026

About

is a lived-experience disability advocacy initiative founded by

eexists to ensure that people with disability, their families and carers are heard within the Australian healthcare system, and that reforms affecting disabled people are assessed through the lens of safety, dignity, human rights and real-world consequences.

ispericularly concerned with the intersection between disability support and healthcare, including hospital discharge risk, gaps between health and NDS responsibilities, support for people with complex needs, social and community participation, safeguarding, informal support pressure, and the importance of lived experience in policy reform.

This submission is distinct from ’s personal submission. It is written from the perspective of as a lived-experience advocacy initiative. It draws on ’s advocacy experience, ’s project work, public submissions to the Senate inquiry, and the concerns raised by people with disability and disability organisations across Australia.

Summary position

supports a sustainable, safe and accountable NDIS. Fraud, exploitation, unsafe providers and misuse of public funds must be addressed. However, is deeply concerned that the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 risks treating “integrity” primarily as a cost-control exercise, rather than a participant safety, rights and safeguarding issue.

’s core position is simple: integrity must include safety. A reform is not truly an integrity measure if it saves money in one system by increasing isolation, health risk, family pressure, carer breakdown, hospitalisation, crisis demand or preventable harm elsewhere.

The Bill should not proceed in its current form unless the Parliament is satisfied that genuine safeguards are in place to protect participants from unsafe loss of supports, reduced choice and control, and being pushed into systems that are not ready or not resourced to meet their needs.

Key concerns

Integrity must not become cost-cutting by another name: Integrity should include fraud control and provider accountability, but it must also include participant safety, fairness, transparency and human rights.
Foundational supports must be built before people are moved out of the NDS: People with disability should not be pushed out of one system before another accessible, properly funded and rights-based system exists.
Choice and control must not be weakened: The NDS was established to give disabled people greater control over their supports. Reforms that reduce flexibility, narrow supports or centralise decision-making risk undermining this foundational principle.
Social and community participation is not a luxury: Community access supports connection, relationships, mental health, work, education, family life, civic participation and safety. Cutting it can create isolation and downstream costs.
Cost shifting must be named and prevented: If NDIS supports are reduced, needs do not disappear. They shift to health, mental health, aged care, housing, crisis services, families, carers and unpaid informal networks.
The health-disability interface remains unsafe: People with disability can fall between health and NDs systems. Reforms must not worsen gaps in clinical support, hospital discharge planning, community-based care and safeguards for people with complex needs.
People with disability must be co-designers, not afterthoughts: The scale of concern across public submissions shows that disabled people and their representative organisations must be central to any redesign.

4. Context: the Bill and the submissions landscape

The Senate referred the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 to the Community Affairs Legislation Committee on 14 May 2026. The official inquiry page records that submissions have closed and that the reporting date is 14 August 2026.

The Department of Health, Disability and Ageing states that the Bill proposes changes to the NDIS Act focused on clarifying eligibility and supports, addressing fraud, and updating governance and administrative arrangements.

 recognises the importance of sustainability and provider integrity. However, the scale and pattern of public concern across submissions demonstrates that people with disability, disability representative organisations, legal and human rights bodies, service providers, health bodies and community organisations are concerned about safety, sequencing, rights and implementation.

The public submission list shared with includes a large number of individual lived-experience submissions, disability representative organisations, legal centres, health and allied health bodies, advocacy organisations, provider organisations and oversight bodies. The list includes, for example, Every Australian Counts, QDN, DANA, Grattan Institute, the Australian Human Rights Commission, Women With Disabilities Australia, QAI, Mental Health Australia, PWDA, Physical Disability Australia, MS Australia, and ’s personal submission.

5. Integrity must include participant safety

 strongly supports action against fraud, exploitation and unsafe provider conduct. People with disability are harmed when public funds are diverted away from their supports, when providers overcharge, when unsafe providers operate without accountability, and when participants are exploited.

However, participant safety must not be treated as separate from integrity. A scheme can lose integrity not only through fraud, but also through decisions that leave people under-supported, isolated, unable to access healthcare, or forced into unsafe informal arrangements.

   is concerned that public debate about the NDIS can frame participants themselves as the problem. This creates fear and stigma. Genuine participants should not be made to feel suspected, excessive, burdensome or guilty for needing disability supports.

Integrity must therefore be measured not only by reductions in expenditure or tighter rules, but by whether people with disability remain safe, connected, supported, and able to exercise choice and control.

6. Foundational supports must exist before people are moved out of the NDIS

   is deeply concerned about proposals and public discussion suggesting that large numbers of people may be moved out of the NDIS or diverted from access to the Scheme. The central question is not only who is technically eligible for the NDIS. It is where people are supposed to go if they lose access to supports they currently rely on.

Foundational supports have been discussed as the alternative. supports the development of strong, accessible, properly funded foundational supports. However, those supports must be real before they are relied upon. They must not be used as a promise after people have already lost NDIS support.

People with disability should not be pushed out of the NDIS into a system that has not yet been built. If foundational supports are not available, accessible, rights-based and adequately funded, people will be left with nowhere to go. Their needs will not disappear. They may simply be shifted onto families, schools, health services, mental health services, aged care, charities, crisis systems or no support at all.

This is not a safe transition. It is a safeguarding risk.

Social and community participation is not a luxury

is particularly concerned about the treatment of social and community participation supports. These supports are sometimes discussed as if they are optional, recreational or less essential than other supports. That misunderstands their role in disabled people’s lives.

Social and community participation can enable people with disability to attend appointments, maintain relationships, visit family, take part in work or volunteering, attend education, access culture and community, participate in civic life, and avoid isolation. For people with limited informal supports, community access support may be the difference between connection and complete isolation.

In ’s personal submission, she explained that social and community access support enables her to visit her father in a nursing home and remain involved in his care. That example demonstrates a broader principle: community access is often family connection, safeguarding, mental health, responsibility and ordinary life - not a luxury.

Reducing social and community participation supports may appear to reduce NDIS spending, but it can increase isolation, distress, health deterioration, crisis service use and family pressure. submits that any reform that reduces these supports must be assessed against its real-world consequences.

Choice and control must not be eroded Choice and control are foundational principles of the NDIS. They are not decorative language. They are the mechanism by which disabled people are able to shape supports around their actual lives, needs, goals, relationships, culture, communication and safety.
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is concerned that reforms which narrow supports, increase ministerial or administrative discretion,
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reduce flexibility, or make decisions less responsive to individual circumstances may erode participant choice and control.

For many people with disability, choice and control is practical. It means choosing supports that allow them to get out of bed, communicate, attend appointments, leave home, manage fatigue or pain, keep a job, stay connected, or participate in family life. When supports are cut or made less flexible, people do not simply “adjust”. Their lives can become smaller and less safe.

 submits that any change to NDIS access, planning, support categories or funding rules must be tested

against a clear question: does this preserve or reduce disabled people’s choice and control?

Cost shifting to other systems is concerned that the Bill may create or worsen cost shifting. If the NDIS reduces support but the person’s needs remain, the costs and risks do not disappear. They move elsewhere.

Reduced disability support can increase pressure on hospitals, emergency departments, primary care, mental health services, housing systems, aged care, child protection, schools, courts, families, carers and unpaid informal networks. This is especially concerning where the receiving systems are already stretched and not designed to provide ongoing disability support.

Cost shifting can also hide harm. A saving to the NDIS may be recorded as fiscal discipline, while the consequences are experienced as isolation, family breakdown, unpaid care, preventable admissions, delayed discharge, or deterioration in health and wellbeing.

 submits that the Parliament should not treat a reform as successful if it reduces NDIS expenditure by

transferring risk to people with disability and other public systems.

10. Health-disability interface and complex needs

’s work is strongly focused on the health-disability interface. Many people with disability experience harm because health and disability systems do not communicate, do not share responsibility, and do not plan together. The result can be unsafe discharge, unmet clinical needs, gaps in care, family burnout, and crisis presentations.

Any NDIS reform must be assessed for its impact on people with complex support needs, medical vulnerability, psychosocial disability, progressive conditions, fluctuating functional needs, communication support needs, and people without reliable informal support.

’ is concerned that reforms which narrow eligibility or supports may particularly harm people who do not fit simple categories. This includes people whose needs sit across disability and health, people whose functioning changes over time, and people whose safety depends on coordinated supports.

The NDIS must not push people into health systems that are not funded or designed to provide disability support. Nor should health systems assume that the NDIS will cover needs that are properly clinical. Reform must reduce the gap between systems, not widen it.

11. Informal supports cannot be assumed

’ is concerned by any approach that assumes families and informal networks can absorb the impact of reduced formal support. Many disabled people do not have reliable informal supports. Others may have family trauma, ageing parents, family members with their own disability or illness, geographic distance, cultural barriers, or caring responsibilities themselves.

Even where families are present, they may not be able to provide safe, ongoing, intensive or specialised support. Reliance on unpaid support can also create burnout, poverty, gendered inequality, relationship strain and risk.

NDIS decisions must assess the real availability, capacity and safety of informal supports. Reform must not shift responsibility onto families by default.

12. Lived experience and co-design

The scale of public response to the Bill shows that people with disability and their representative organisations want reform to be done with them, not to them.’ submits that genuine co-design cannot be rushed, tokenistic or confined to consultation after major decisions have already been made.

People with disability must be involved in defining the problem, designing safeguards, testing implementation, monitoring harm, and evaluating whether reforms are working. This includes people with communication disability, intellectual disability, psychosocial disability, complex needs, culturally and linguistically diverse communities, First Nations disabled people, women and girls with disability, people in regional and remote areas, and people with limited informal supports.

Policy designed without disabled people is more likely to miss real-world risk.

13. Recommendations

Do not proceed with the Bill in its current form unless participant safety safeguards are strengthened. The Bill should be amended or delayed until the Parliament can be satisfied that genuine participants will not lose essential supports or be pushed into unsafe gaps.
Build foundational supports before relying on them as an alternative to the NDIS. People should not be moved out of the NDIS until foundational supports are accessible, properly funded, available nationally, rights-based and capable of meeting real needs.

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Protect choice and control as a core test for all reforms. Any change to access, planning, support categories or funding rules should be tested against whether it preserves participant choice and control.
Protect social and community participation supports. Community access should not be treated as optional. Its role in preventing isolation, supporting family connection, enabling work and safeguarding wellbeing must be recognised.
Require a cost-shifting and harm assessment. The Government should publish analysis of the likely impact on health, mental health, aged care, housing, crisis services, carers, families and state and territory systems.
Strengthen health-disability interface safeguards. The Bill should include protections for people whose needs sit across disability and health, including people with complex, progressive, fluctuating or clinical support needs.
Do not assume informal supports. Planning and access decisions must assess actual informal support capacity, not rely on assumptions about family availability.
Embed genuine co-design and lived-experience oversight. Disabled people and disability representative organisations must have real power in redesign, implementation, monitoring and review.
Protect review rights and transparency. Participants must be able to understand, challenge and review decisions that affect their supports.
Prioritise fraud and provider integrity measures that do not punish participants. The strongest integrity response is to pursue fraud, exploitation and unsafe providers without reducing supports for genuine participants.

14. Suggested amendments / safeguards

recommends that the Committee consider whether the Bill requires explicit safeguards to prevent people losing essential supports before alternatives exist. These safeguards could include:

a statutory no-worse-off transition principle for existing participants until equivalent supports are available and accessible;
a requirement that foundational supports be independently assessed as operational before any large-scale transition from the NDIS;
an obligation to consider participant safety, family connection, community access, communication, health risks and informal support limits before reducing supports;
mandatory publication of modelling about who will be affected and which systems will absorb demand;
specific protections for people with complex needs, psychosocial disability, progressive conditions, fluctuating functional capacity and limited informal supports;
clear review rights and accessible reasons for decisions;
an independent lived-experience oversight mechanism to monitor harm during implementation.

15. Conclusion

 supports a sustainable and accountable NDIS. We support action against fraud, exploitation and unsafe providers. But integrity cannot be defined only through reduced expenditure, tighter eligibility or fewer supports.

The NDIS was created because people with disability need support to live safely, equally and with dignity. A scheme that protects public money but leaves participants isolated, unsupported, afraid or pushed between systems is not a scheme with true integrity.

Appendix A: How this submission aligns with public submission themes

Theme Foundational supports not ready AHRC, PWDA, QAI, advocacy and lived-experience submissions system consequences. Choice and control submissions, rights bodies safety, rights, real-world impacts and system consequences. Cost shifting state/territory-related concerns, health and community organisations system consequences. Social and community participation Australian Counts, PWDA, physical disability and community organisations system consequences. Health-disability interface National Alliance, MS Australia, Mental Health Australia, Palliative Care Australia, health/allied health submissions Human rights and review safeguards centres, DANA, PWDA system consequences. Lived experience and co-design Counts, participant submissions, disability advocacy organisations system consequences. Examples of submissions/sources How uses this theme Every Australian Counts, QDN, DANA, Supports ’s position that integrity reform must be assessed through safety, rights, real-world impacts and PWDA, QDN, QAI, DANA, personal Supports ’s position that integrity reform must be assessed through Ombudsman, legal and rights bodies, Supports ’s position that integrity reform must be assessed through safety, rights, real-world impacts and Participant submissions, QDN, Every Supports ’s position that integrity reform must be assessed through safety, rights, real-world impacts and Young People in Nursing Homes Supports ’s position that integrity reform must be assessed through safety, rights, real-world impacts and system consequences. Australian Human Rights Commission, Supports ’s position that integrity QAI, Advocacy for Inclusion, legal reform must be assessed through safety, rights, real-world impacts and DRO submissions, Every Australian Supports ’s position that integrity reform must be assessed through safety, rights, real-world impacts and

Appendix B: Priority submissions / sources for reference

Submission/source Submission number / note Every Australian Counts Submission 268 Queenslanders with Disability Network Submission 273 Disability Advocacy Network Australia Submission 275 Grattan Institute Submission 276 Australian Human Rights Commission Submission 287 Women With Disabilities Australia Submission 331 Queensland Advocacy for Inclusion Submission 375 Mental Health Australia Submission 380 People with Disability Australia Submission 381 Physical Disability Australia Submission 421 MS Australia Submission 438 Commonwealth Ombudsman Submission 248 Young People in Nursing Homes National Alliance Submission 255 Occupational Therapy Australia Submission 285 personal submission Submission 163

Appendix C: Public advocacy lines can use

Integrity must not mean isolation.
Integrity without safety is not integrity.
People with disability should not be pushed into a system that has not yet been built.
Social and community participation is not a luxury - it is how people stay connected, safe and part of ordinary life.
The need does not disappear when NDIS funding is cut; the cost and risk move somewhere else.
The NDS should protect public money and protect the people it was created to support.
Reform must be done with disabled people, not to disabled people.