Securing the Future of the NDIS Through Better Decision-Making (Provider experience)

Securing the Future of the NDIS Through

Better Decision-Making

A Frontline Perspective from a Social Worker and Positive

Behaviour Support Practitioner

Submission to the Senate Community Affairs Legislation Committee

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for

Future Generations) Bill 2026

Executive Summary

I welcome the Australian Government’s commitment to ensuring the long-term sustainability of the National Disability Insurance Scheme (NDIS). A sustainable Scheme is essential to protect the rights of current participants while ensuring future generations of Australians with disability can continue to access the supports they need.

As a Social Worker and Positive Behaviour Support

Practitioner with more than ten years’ experience across disability, mental health, education and community services, I have seen firsthand the profound difference that timely, evidence-based supports can make. I have also observed the consequences of inconsistent planning decisions, limited disability knowledge, delayed access to supports and insufficient collaboration between planners and treating professionals.

In my view, the sustainability of the NDIS will not be achieved solely through tighter funding controls or increased administrative requirements. Long-term

sustainability depends equally on improving the quality of decision-making. Accurate decisions made early reduce unnecessary reviews, appeals, crisis responses, hospital admissions, provider breakdowns and restrictive practices. They also ensure participants receive the supports they require to maintain independence, safety and community participation.

The purpose of this submission is not to criticise the objectives of the Bill, but to propose practical amendments that strengthen its implementation while preserving the principles upon which the NDIS was established

Key Recommendations

This submission makes the following key recommendations to strengthen the implementation of the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 while supporting the long term sustainability of the Scheme:

• Improve the quality and consistency of planning decisions by investing in planner capability, disability specific education and ongoing professional development.

• Prioritise the recruitment of planners and delegates with relevant qualifications or experience in social work, psychology, occupational therapy, speech pathology, nursing or other allied health and human services professions.

• Establish a Clinical Advisory Service within the NDIA to enable planners to consult appropriately qualified clinicians when making decisions involving complex disability presentations or specialist clinical issues.

• Strengthen collaboration between planners and treating professionals by ensuring clinical reports are meaningfully considered and clinicians are consulted where clarification is required before significant decisions are made.

• Improve the assessment of functional capacity by recognising the impact of environmental, psychological and social factors, and by considering multiple sources of evidence gathered over time rather than relying on a single assessment or point-in-time observation.

• Ensure planning processes appropriately recognise progressive, degenerative and fluctuating disabilities, including reducing unnecessary reassessments where deterioration is clinically expected and recognising maintenance of independence and quality of life as meaningful outcomes.

• Ensure participants are not disadvantaged where recommended treatment or mainstream services are unavailable, inaccessible or inappropriate, and recognise real-world barriers to accessing healthcare.

• Promote early intervention and evidence-based supports that prevent crisis, reduce restrictive practices, maintain independence and improve long-term participant outcomes.

• Improve transparency by providing clear reasons where recommendations from appropriately qualified treating professionals are not accepted.

• Recognise that improving the quality, consistency and evidence base of planning decisions is itself a key strategy for securing the long-term sustainability of the NDIS.

1. Improving Decision-Making: Why Planner

Expertise Matters

The long-term sustainability of the NDIS depends not only on managing expenditure, but also on ensuring that planning decisions are accurate, evidence-based and informed by an appropriate understanding of disability. Poor decisions are costly—not only for participants, but for the Scheme itself. Inaccurate funding decisions can lead to unnecessary reviews, appeals, provider breakdowns, hospital admissions, safeguarding concerns and increased reliance on crisis responses. Investing in better decision making is therefore an investment in the long-term sustainability of the NDIS.

The role of an NDIS planner is complex. Planners make decisions that significantly influence a participant’s independence, health, safety and quality of life while balancing legislative requirements, participant needs and the financial sustainability of the Scheme. This is an enormous responsibility, and planners should be supported with the knowledge, training and access to clinical expertise necessary to make informed decisions.

Disability is rarely straightforward. A participant’s functional capacity is not determined solely by their diagnosis but by the interaction between their impairment

and a range of environmental, psychological and social factors. Housing, trauma, communication differences, mental health, physical health, informal supports, access to services and community participation all influence how disability affects everyday life. Understanding these interactions requires specialised knowledge.

Professionals such as social workers, psychologists, occupational therapists, speech pathologists, nurses and other allied health practitioners are specifically trained to assess functional capacity, understand the interaction between disability and environment, identify psychosocial barriers and apply person-centred, strengths-based approaches. Their expertise is highly relevant to the decisions made within the NDIS and should be better utilised throughout the planning process.

Planners should not be expected to know everything about every disability. However, they should be expected to recognise when specialist expertise is required and to meaningfully engage with the clinicians who have assessed and supported the participant over time. Collaboration between planners and treating professionals should be viewed as a strength of the Scheme, not an exception.

Just as multidisciplinary consultation is considered best practice throughout healthcare and allied health, the NDIA should establish a formal clinical consultation mechanism that enables planners and delegates to seek advice from appropriately qualified professionals when making decisions involving complex disability presentations or specialist clinical issues. This would support planners to make more accurate and consistent decisions while recognising that no single professional can possess expertise across every disability, condition and clinical presentation.

In my own practice, I have observed situations that demonstrate why disability-specific knowledge is essential. During one planning discussion, I was advised that

dementia “can get better.” Dementia is a progressive neurodegenerative condition. While appropriate supports can maximise independence, improve quality of life and reduce distress, the underlying condition does not improve. This example is not shared to criticise an individual planner, but to highlight a broader systemic issue. If a planner has an incomplete understanding of a progressive neurological condition such as dementia, there is a genuine risk that a participant’s current and future support needs will be underestimated. This may result in inadequate funding, increased pressure on informal carers, avoidable crises and ultimately higher long-term costs to the Scheme.

Equally important is the meaningful consideration of clinical evidence.

Behaviour Support Plans, Functional Behaviour

Assessments, Functional Capacity Assessments and other

allied health reports are commissioned to provide the NDIA with evidence-based recommendations that support informed decision-making. These reports are not administrative paperwork or opinion pieces.

As clinicians, we do not prepare comprehensive assessments because we “feel like it.” These reports often represent many hours of interviews, direct observations, standardised assessment tools, consultation with participants, families and multidisciplinary teams, behavioural data analysis, review of historical information and detailed clinical reasoning. They are prepared to provide the NDIA with an accurate understanding of a participant’s functional capacity, support needs and the barriers affecting their daily life.

These reports exist to assist the NDIA in making informed decisions. Their value is diminished if they are not meaningfully considered during the planning process.

Planning decisions should meaningfully consider the recommendations contained within these reports. Where planners have questions, require clarification or are considering reaching a different conclusion, there should be an expectation that they contact the treating clinician before making a determination. This collaborative approach would improve the accuracy and consistency of decisions, reduce misunderstandings and ensure funding decisions are based on the best available evidence.

The current planning process can also inadvertently duplicate assessments that have already been completed by treating professionals. Participants are often required to repeatedly demonstrate the impact of their disability despite comprehensive evidence already existing. Rather than recreating clinical assessments, the NDIA should seek to maximise the value of existing evidence by working collaboratively with those who know the participant best. This would reduce duplication, improve efficiency and lessen the administrative burden on participants, families and providers.

Where clinical recommendations are not accepted, participants and treating professionals should receive a clear explanation outlining how the evidence was considered and why an alternative decision was reached. Transparent decision-making would strengthen accountability, improve confidence in the Scheme and reduce unnecessary internal reviews and appeals.

Where reasonably practicable, planners should also meet participants in person before making significant decisions regarding eligibility, funding or major plan changes. Observing participants within their everyday environment often provides valuable insights that cannot be captured through documentation or telephone conversations alone. Where an in-person meeting is not possible, meaningful consultation with treating clinicians and key members of the participant’s support network should occur before significant decisions are made.

Improving planner capability is not simply an investment in workforce development—it is an investment in the long term sustainability of the NDIS. Better-informed decisions are more likely to result in appropriate supports being funded from the outset, reducing internal reviews, appeals, repeated reassessments and administrative costs. More importantly, they help prevent participant deterioration resulting from inadequate supports, reducing costly hospital admissions, safeguarding interventions, emergency accommodation, provider breakdowns and the use of restrictive practices.

Ultimately, better decision-making saves money. By investing in planner capability, valuing clinical expertise and embedding genuine collaboration into the planning process, the Australian Government can improve participant outcomes while achieving the Bill’s objective of securing the NDIS for future generations.

Recommendations

• Prioritise the recruitment of planners and delegates with qualifications or substantial experience in social work, psychology, occupational therapy, speech pathology, nursing or other relevant allied health or human services professions.

• Introduce mandatory training in disability, psychosocial disability, progressive neurological conditions, trauma-informed practice, neurodiversity, communication differences and supported decision making.

• Require planners to meet participants in person wherever reasonably practicable before making significant eligibility or funding decisions.

• Require planners to meaningfully consider allied health reports and other clinical evidence as part of the planning process.

• Where clarification is required, require planners to consult directly with treating clinicians before making significant decisions.

• Where recommendations are not adopted, provide participants with a clear explanation of how the evidence was considered and the reasons for the decision.

• Reduce duplication by maximising the use of existing clinical assessments and evidence wherever appropriate.

• Recognise improved decision-making and clinical collaboration as key strategies for enhancing both

participant outcomes and the long-term financial sustainability of the NDIS.

2. Respecting Clinical Evidence and

Professional Recommendations

The NDIS relies on evidence-informed decision-making. Participants are frequently required to obtain reports from

Behaviour Support Practitioners, Occupational Therapists,

Psychologists, Speech Pathologists, Physiotherapists, Social

Workers and other allied health professionals to demonstrate their functional capacity and support needs.

These reports are commissioned because they provide expert clinical evidence. They are not simply administrative requirements, nor are they opinion pieces. They represent comprehensive assessments developed through direct observation, interviews, standardised assessment tools, consultation with participants, families and multidisciplinary teams, analysis of historical information and the application of professional judgement.

As clinicians, we do not prepare comprehensive assessments because we “feel like it.” Many reports require numerous hours of assessment, consultation, analysis and documentation to accurately reflect a participant’s strengths, support needs and the barriers affecting their daily life. They are prepared to assist the NDIA in making informed, evidence-based decisions.

Clinical reports should not be treated as documents that participants are required to obtain simply to satisfy an administrative process. They should be recognised for what they are

intended to be: expert evidence that informs sound, transparent and evidence-based decision making.

The value of these reports is significantly diminished if they are not meaningfully considered during the planning process.

While the NDIA must ultimately make independent funding decisions, those decisions should be informed by the professionals who have spent the greatest amount of time assessing and supporting the participant. In many cases, treating clinicians have developed an in-depth understanding of the participant over months or years. This longitudinal understanding cannot always be replicated through a single planning meeting or review of documentation.

Where planners have questions about the evidence, require clarification or are considering reaching a different conclusion to that of the treating professional, there should be an expectation that they contact the clinician before making a determination. Open communication between planners and treating professionals should be encouraged as standard practice, particularly where decisions may significantly affect a participant’s access to supports.

Equally, where the NDIA decides not to accept recommendations made by appropriately qualified treating professionals, participants should receive a clear explanation outlining how the evidence was considered and the reasons an alternative decision was reached. Transparent decision-making promotes accountability,

improves participant confidence in the Scheme and reduces unnecessary disputes.

The planning process should also seek to reduce duplication of assessment wherever possible. Participants are often required to repeatedly demonstrate the impact of their disability despite comprehensive evidence already existing. This can create unnecessary stress, increase costs for the Scheme and place additional administrative burdens on participants, families and providers. Greater reliance on existing high-quality clinical evidence would improve efficiency while maintaining robust decision-making.

Strengthening collaboration between planners and treating professionals would improve the quality, consistency and transparency of planning decisions. It would also reduce avoidable internal reviews, external appeals and delays in accessing appropriate supports. Better use of existing clinical evidence is not simply good administrative practice —it is an important strategy for improving participant outcomes and supporting the long-term sustainability of the NDIS.

Recommendations

• Require planners and delegates to meaningfully consider all relevant clinical evidence submitted as part of a participant’s application or plan review.

• Encourage direct consultation with treating clinicians where clarification of evidence is required before significant funding or eligibility decisions are made.

• Where clinical recommendations are not accepted, provide participants with a clear written explanation

outlining how the evidence was considered and the reasons for the decision.

• Reduce unnecessary duplication by maximising the use of existing high-quality clinical assessments wherever appropriate.

• Strengthen collaboration between the NDIA and treating professionals to improve the consistency, transparency and quality of planning decisions.

3. Recognising the Complexity of Functional

Capacity

The NDIS is founded on the principle of supporting people based on how their disability affects their functional capacity. For this reason, it is essential that assessments accurately reflect the realities of a participant’s daily life.

Functional capacity is not static. Many participants experience significant variation in their functioning depending on environmental demands, fatigue, mental health, physical health, communication supports, sensory factors, available informal supports and other contextual influences. This is particularly evident for people living with psychosocial disability, progressive neurological conditions, acquired brain injury and other fluctuating or episodic disabilities.

A single assessment, brief meeting or isolated observation may not accurately represent a participant’s usual level of functioning. Participants often present differently depending on the environment they are in, who is present,

whether they are experiencing a “good day” or a “bad day”, and the supports currently available to them.

As a Positive Behaviour Support Practitioner, I regularly observe participants across multiple environments and over extended periods of time. It is common for a participant’s presentation during a short appointment to differ significantly from what is experienced at home, in the community or during periods of increased stress. This highlights the importance of considering evidence gathered over time rather than relying on a single point-in-time assessment.

Assessment processes should recognise that disability is influenced not only by diagnosis, but also by the interaction between the individual and their environment. This reflects contemporary understandings of disability and aligns with person-centred practice. A participant’s ability to function in one setting should not be assumed to represent their ability to function across all aspects of daily life.

Decision-makers should therefore consider multiple sources of evidence, including longitudinal observations, reports from treating clinicians, allied health assessments, behavioural data, participant and family perspectives, and information from support providers who regularly observe the participant in their everyday environments.

A more comprehensive approach to assessing functional capacity is likely to improve the accuracy and consistency of planning decisions while reducing disputes about eligibility and funding. It also ensures that supports are

based on a participant’s genuine level of need rather than a single interaction or assessment.

Investing in thorough and evidence-based functional assessments is not only beneficial for participants—it also supports the long-term sustainability of the NDIS by reducing inappropriate funding decisions, repeated reassessments and avoidable reviews.

Recommendations

• Recognise that functional capacity should be assessed using multiple sources of evidence rather than a single assessment or observation.

• Ensure assessment processes appropriately account for fluctuating, episodic and progressive disabilities.

• Require decision-makers to consider longitudinal evidence gathered over time by treating clinicians and allied health professionals.

• Recognise the influence of environmental, psychological and social factors on functional capacity.

• Encourage planning decisions that reflect a participant’s everyday functioning across different settings, rather than isolated observations

4. Supporting Participants with Progressive

and Fluctuating Disabilities

While some disabilities remain relatively stable over time, others are progressive, degenerative or fluctuate significantly. Planning processes should recognise these differences to ensure participants receive timely and appropriate supports throughout the course of their condition.

Participants living with conditions such as dementia, Parkinson’s disease, multiple sclerosis, Huntington’s disease, motor neurone disease and certain acquired neurological conditions are likely to experience a gradual decline in functional capacity. Similarly, participants with psychosocial disability and other episodic conditions may experience periods of significant deterioration followed by periods of relative stability.

Planning processes should reflect the expected trajectory of these conditions rather than relying solely on a participant’s current presentation. Where there is clear clinical evidence that a condition is progressive, planning decisions should anticipate increasing support needs and minimise the need for participants and families to repeatedly demonstrate deterioration before additional supports are considered.

Repeated reassessments can place considerable emotional, financial and administrative burdens on participants and their families. For individuals living with progressive conditions, requiring them to continually prove that their disability has worsened can be both distressing and unnecessary when the natural progression of the condition is well established within the medical literature.

The planning process should also recognise that maintaining a person’s current level of functioning is often a successful outcome. For many participants with progressive conditions, the goal of support is not to improve the underlying condition, but to preserve independence, maximise quality of life, reduce distress, delay functional decline where possible and support continued participation in family and community life.

Funding decisions should therefore acknowledge the preventative value of early and appropriate supports. Delaying access to essential services until a participant reaches crisis point often results in poorer outcomes and significantly greater costs through hospital admissions, emergency interventions, carer breakdown, safeguarding concerns and the loss of independence.

Recognising the nature of progressive and fluctuating disabilities is consistent with both good clinical practice and the objective of securing the long-term sustainability of the NDIS. Providing appropriate supports before a crisis develops is not only more humane but also represents a more efficient use of public resources.

Recommendations

• Ensure planning processes recognise the progressive nature of neurodegenerative conditions and other disabilities where increasing support needs can reasonably be anticipated.

• Reduce unnecessary reassessments for participants with well-established progressive conditions where ongoing deterioration is clinically expected.

• Recognise maintenance of functional capacity, quality of life and independence as important outcomes, even where improvement in the underlying condition is not possible.

• Enable timely plan reviews where participants experience significant deterioration in functioning or increased risk.

• Prioritise preventative and early supports that reduce the likelihood of crisis responses, hospital admissions and other high-cost interventions.

5. Recognising Barriers to Treatment and

Mainstream Services

The long-term sustainability of the NDIS depends on ensuring participants receive appropriate supports while also making the best use of mainstream health, mental health and community services. Where effective mainstream services are available and accessible, they should continue to play an important role in supporting people with disability.

However, planning decisions must also reflect the realities of Australia’s healthcare system.

Many participants experience significant barriers to accessing recommended treatment, including lengthy public waitlists, workforce shortages, high out-of-pocket costs, limited availability of specialist services, geographical isolation and transportation difficulties. Others may have communication needs, trauma histories or behavioural presentations that make accessing traditional health services particularly challenging.

For these participants, the existence of a service in theory does not mean that it is genuinely accessible in practice.

Participants should not be disadvantaged because they are unable to access treatment that is unavailable, unaffordable or clinically unsuitable. Likewise, families should not be

expected to shoulder the burden of navigating fragmented systems or waiting years for services before appropriate disability supports can be considered.

Planning decisions should recognise the distinction between disability-related supports funded through the NDIS and healthcare services funded through mainstream systems. At the same time, they should acknowledge that the effectiveness of this boundary depends on mainstream services being available in a timely and meaningful way.

Where access to appropriate treatment is limited by factors beyond a participant’s control, decision-makers should consider these barriers as part of the planning process rather than assuming treatment has simply not been pursued.

Greater collaboration between the NDIA, health services and treating professionals would also improve continuity of care and reduce the risk of participants falling between service systems.

Ultimately, sustainability should not be achieved by expecting participants to access services that are unavailable. Rather, it should be achieved by recognising real-world barriers, improving coordination across systems and ensuring participants receive the supports they reasonably require to maintain their safety, independence and participation.

Recommendations

• Recognise that treatment should be considered “appropriate” only where it is reasonably accessible, clinically indicated and acceptable to the participant.

• Require planners to consider documented barriers to accessing treatment, including waitlists, cost, workforce shortages, geography and trauma-related barriers.

• Strengthen collaboration between the NDIA, treating clinicians and mainstream health services when determining participant support needs.

• Ensure participants are not disadvantaged where mainstream services are unavailable or unable to meet disability-related needs within a reasonable timeframe.

• Recognise that improving coordination between the NDIS and mainstream systems supports both participant outcomes and the long-term sustainability of the Scheme.

Summary of Recommendations

To strengthen the National Disability Insurance Scheme

Amendment (Securing the NDIS for Future Generations) Bill 2026 while supporting the long-term sustainability of the Scheme, I respectfully recommend that the Committee consider the following amendments and implementation measures. Planner capability and decision-making

1. Prioritise the recruitment of planners and delegates with qualifications or substantial experience in social work, psychology, occupational therapy, speech

pathology, nursing or other relevant allied health or human services professions.

2. Introduce mandatory and ongoing training in disability, psychosocial disability, progressive neurological conditions, trauma-informed practice, neurodiversity, communication differences, supported decision-making and person-centred practice.

3. Require planners to meet participants in person wherever reasonably practicable before making significant eligibility or funding decisions.

4. Encourage continuity by allocating participants a consistent planner wherever possible, allowing planners to develop a stronger understanding of participants’ evolving needs over time.

5. Establish a Clinical Advisory Service within the NDIA to enable planners and delegates to consult appropriately qualified allied health professionals when making decisions involving complex disability presentations, progressive neurological conditions, psychosocial disability, significant behavioural support needs or conflicting clinical evidence. Clinical evidence and collaboration

6. Require planners to meaningfully consider all relevant clinical evidence submitted as part of a participant’s application or plan review.

7. Where clarification is required, require planners to consult directly with treating clinicians before making significant funding or eligibility decisions.

8. Where recommendations made by appropriately qualified clinicians are not accepted, provide participants with a clear written explanation outlining how the evidence was considered and the reasons for the decision.

9. Reduce unnecessary duplication by maximising the use of existing high-quality clinical assessments wherever appropriate. Functional assessment

10.Ensure functional capacity assessments consider multiple sources of evidence rather than relying on a single assessment or point-in-time observation.

11.Recognise the influence of environmental, psychological and social factors on functional capacity.

12.Ensure assessment processes appropriately account for fluctuating, episodic and progressive disabilities. Progressive and fluctuating disability

13.Recognise the progressive nature of neurodegenerative conditions and other progressive disabilities when making planning decisions.

14.Reduce unnecessary reassessments where deterioration is clinically expected and well documented.

15.Recognise maintenance of independence, safety and quality of life as meaningful outcomes where improvement in the underlying condition is not possible.

16.Introduce priority review pathways for participants experiencing significant deterioration in functioning or increased risk. Access to treatment and mainstream services

17.Recognise treatment as “appropriate” only where it is reasonably accessible, clinically indicated and acceptable to the participant.

18.Ensure participants are not disadvantaged where mainstream services are unavailable, inaccessible or unable to meet disability-related needs within a reasonable timeframe.

19.Strengthen collaboration between the NDIA and mainstream health services to improve continuity of care. Long-term sustainability

20.Recognise early intervention and preventative supports as investments that improve participant outcomes and reduce long-term Scheme expenditure.

21.Measure the success of the NDIS using participant outcomes alongside financial sustainability, including reduced crisis presentations, improved independence,

reduced restrictive practices, increased community participation and participant satisfaction.

22.Recognise that improving the quality, consistency and evidence base of planning decisions is itself a key strategy for securing the long-term sustainability of the NDIS.

Concluding Remarks

I welcome the Australian Government’s commitment to securing the long-term sustainability of the National Disability Insurance Scheme. A sustainable NDIS is essential to ensure current and future generations of Australians with disability can continue to access the supports they need to live safe, meaningful and inclusive lives.

The recommendations presented in this submission are not intended to oppose reform, but to strengthen its implementation. They are informed by my professional experience as a Social Worker and Positive Behaviour Support Practitioner working alongside participants, families, support providers and multidisciplinary teams across a range of complex disability presentations.

Throughout my practice, I have seen the life-changing impact of timely, evidence-based supports. I have also seen the consequences when participant needs are underestimated, clinical expertise is not fully utilised, or planning decisions are made without a comprehensive understanding of how disability affects everyday functioning. These situations not only impact participants

and their families but can also lead to increased costs through avoidable reviews, appeals, provider breakdowns, crisis responses and hospital admissions.

One of the strongest opportunities to improve the long-term sustainability of the NDIS is to strengthen the quality of decision-making. This means investing in planner capability, recognising the expertise of treating clinicians, meaningfully considering clinical evidence, improving collaboration and ensuring planning processes reflect the complexity and diversity of disability.

No single professional can be expected to possess expert knowledge of every disability or clinical presentation. However, planners should be supported to recognise when specialist expertise is required and be empowered to collaborate with the professionals who know the participant best. Better decisions are made when expertise is shared.

Ultimately, the sustainability of the NDIS should not be measured solely by expenditure. It should also be measured by the Scheme’s ability to make accurate, transparent and evidence-informed decisions that improve participant outcomes, reduce unnecessary administrative burden and prevent avoidable crises.

The NDIS represents one of Australia’s most significant social reforms. Protecting its future requires not only responsible financial stewardship, but also confidence that planning decisions are informed by evidence, guided by expertise and centred on the lived experience of people with disability.

The future of the NDIS will be secured not only by managing costs, but by making the right decisions the first time. When decisions are informed by evidence, strengthened through collaboration and grounded in a genuine understanding of disability, participants receive the supports they need, public resources are used more effectively, and the Scheme is strengthened for future generations.