National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1657

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1657

1. Primary Diagnosis Only – Removal of Secondary Disabilities and Comorbidities

The proposed shift toward recognising only a participant’s “primary diagnosis” fundamentally misunderstands the complexity of disability and the lived experience of people with multiple intersecting impairments. It risks creating an artificial and clinically unsafe distinction between disabilities that do not operate independently in real life.

This is particularly concerning for people living with Deafblindness and dual sensory loss, who frequently present with additional intellectual, neurological, psychosocial or physical disabilities. A model which permits support funding only against a single “primary diagnosis” would result in supports that are incomplete, ineffective and ultimately not fit for purpose.

For example, where a participant is recorded only as having vision impairment, they may receive vision-related supports alone. However, a person who is deafblind cannot safely or meaningfully access many vision-specific interventions without communication access, environmental modification, specialist orientation support, interpreter services or dual sensory adapted approaches. The interaction between hearing and vision loss creates a distinct disability experience that cannot be separated into isolated categories without materially diminishing outcomes.

Further concern exists regarding the increasing use of automated or AI-assisted allocation systems aligned to diagnosis categories. If funding allocations become narrowly linked to a simplified diagnostic profile, participants with complex overlapping disabilities are likely to receive standardised supports that fail to reflect their actual functional needs, communication methods, environmental barriers and safeguarding risks.

It is also deeply concerning that Deafblindness itself has been omitted from some primary diagnosis listings and discussion papers. Deafblindness is internationally recognised as a distinct disability requiring specialised intervention and expertise. Any future inclusion must extend beyond narrow diagnostic categories such as Usher Syndrome or CHARGE Syndrome and align instead with internationally recognised functional frameworks such as the WHO International Classification of Functioning, Disability and Health (ICF) Core Sets.

The consequence of these proposed changes is not administrative simplification. It is the exclusion of people with complex disability from meaningful participation, safety, communication and independence.

Specialist providers operating in low-volume, high-complexity markets such as deafblindness already face significant workforce, training and sustainability challenges. Reducing participant eligibility or artificially narrowing support categories will further destabilise specialist service ecosystems that are already under pressure. Once specialist capability is lost, it is extraordinarily difficult and costly to rebuild.

The Committee should strongly consider that complexity-based disability support may cost more upfront, but failure to provide appropriate integrated support creates substantially greater downstream costs through:

 increased health system utilisation;

 mental health deterioration;

 social isolation;

 safeguarding failures;

 carer breakdown;

 avoidable hospital admissions;

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1657

 homelessness risk; and

 premature entry into more intensive and restrictive support environments.

The NDIS was established specifically to recognise disability as a lifelong functional reality requiring investment and inclusion. Narrowing access through simplistic diagnostic categorisation represents a fundamental departure from that founding principle.

2. Functional Eligibility Rather Than Diagnosis

The proposed increased emphasis on “functional impairment” rather than diagnosis is presented publicly as a reform measure; however, from an operational and participant perspective, this is not a new approach. Participants already face significant evidentiary burdens in demonstrating functional impact beyond diagnosis alone.

Current access processes already require extensive evidence across multiple life domains, often including:

 functional capacity assessments;

 allied health reports;

 communication assessments;

 mobility assessments;

 behavioural evidence;

 psychosocial impact statements; and

 detailed descriptions of daily living limitations.

In practice, many participants are already being required to privately fund extensive Functional Capacity Assessments (FCAs) simply to access the Scheme. This creates a deeply inequitable situation whereby people with disability must spend substantial personal funds to prove eligibility for support that was intended to be universally accessible based on need.

This disproportionately impacts people with sensory disabilities, including Deafblindness, where functional limitations may fluctuate depending on:

 environmental conditions;

 fatigue;

 communication access;

 assistive technology;

 interpreter availability; and

 community supports.

There is also significant concern that generic FCA frameworks are frequently not equipped to assess dual sensory loss appropriately. Many assessors do not possess specialist deafblind capability, resulting in participants being inaccurately assessed as more “capable” than they functionally are in real-world environments.

The increased emphasis on functional evidence risks creating:

 longer wait times;

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1657

 increased administrative burden;

 greater participant distress;

 increased costs shifted onto individuals and families; and

 inequitable access outcomes based on financial means.

This is inconsistent with the intent of the NDIS as a nationally accessible insurance scheme.

If Government wishes to strengthen functional assessment processes, investment must first occur in:

 specialist assessment pathways;

 nationally consistent frameworks;

 accessible evidence processes;

 culturally safe approaches; and

 publicly funded access assessment supports.

Without this, the practical outcome is simply the transfer of financial and evidentiary burden onto people with disability and their families.

3. Proposed Reduction of Community Access and Participation Supports

The signalling of reforms that may restrict Community Access and Participation Supports (CAS) to “life preserving” functions represents one of the most concerning policy directions currently under discussion.

For people with sensory disability, Deafblindness and dual sensory loss, community participation is not an optional lifestyle enhancement. It is often the critical protective factor preventing profound social isolation, mental health deterioration and disengagement from society.

Supports such as:

 AUSLAN interpreters;

 support workers;

 communication guides;

 communication support;

 transport assistance;

 orientation assistance; and

 community access facilitation

are the mechanisms through which people with deafblindness can:

 work;

 volunteer;

 maintain social relationships;

 attend medical appointments;

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1657

 engage in civic life;

 access education;

 shop independently;

 participate in recreation; and

 maintain basic autonomy and dignity.

Restricting supports to “life preserving” functions alone effectively reduces disability support to survival rather than participation.

This is inconsistent with:

 the objects and principles of the NDIS Act;

 the UN Convention on the Rights of Persons with Disabilities; and

 the broader Australian commitment to social inclusion and equal participation.

The practical consequence of these reforms would be increased exclusion of people who are already among the most socially isolated cohorts in the community.

A person who is deafblind may physically survive without access to interpreters, support workers or community engagement supports. However, without those supports they may lose:

 employment;

 social connection;

 independence;

 communication access;

 community participation; and

 meaningful quality of life.

This is not a theoretical concern. It represents a direct pathway toward:

 worsening mental health outcomes;

 increased depression and anxiety;

 increased reliance on acute health systems;

 carer fatigue and breakdown;

 reduced workforce participation; and

 higher long-term government expenditure.

The framing of these supports as “non-essential” fundamentally misunderstands the role of disability support in enabling equal citizenship.

The NDIS was not created solely to keep people alive. It was created to enable people with disability to live ordinary lives with dignity, participation and inclusion comparable to other Australians.

Specialist providers delivering services to low-incidence disability groups such as Deafblindness already operate within fragile funding environments requiring significant specialist workforce capability, training investment and communication expertise. Reducing funding in these areas risks

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1657

market collapse and the loss of specialist knowledge that mainstream services are often unable to replicate safely or effectively.

Government cannot simultaneously:

 establish the NDIS as a rights-based inclusion framework;

 encourage workforce and community participation; and

 then materially reduce the supports that make such participation possible.

The long-term social and economic costs of exclusion will substantially outweigh any short-term budget savings generated through these proposed reforms.