Submission

Submission: The National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 - By Tim and Emily Pryde; May 23rd, 2026

Executive Summary

This document outlines significant risks associated with amendments intended to expand provider registration requirements under Section X of Y Act Z. Registration is highlighted as insufficient protection against poor quality services due to its inability to ensure continuous support from knowledgeable professionals who can adapt their approach based upon deep relational knowledge rather than administrative compliance alone; families are already experiencing pressure towards using exclusively registered providers which could further limit choices available especially among those requiring highly specialized attention, such individuals often rely solely within small-scale enterprises where they may be unable financially absorb additional regulatory burdens imposed thereby potentially leading into market collapse or increased financial strain on participants.

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

Submission 174

Registration is not a universal safeguard

We acknowledge the legitimate intent behind safeguarding measures. However, registration alone does not guarantee safety, quality, or competence. For participants with high and complex needs, safety is derived from:

• deep long-term understanding of the participant
• consistent communication partners
• trust built over time
• attuned responses to distress and escalation These natural safeguards cannot be replicated through compliance frameworks audits paperwork. In some casesover-relianceonregistrationcreatesafalse senseofsecurity shifting focusfrom real-worldsafetoyadministrativecompliance.Theproposedamendmentsriskembeddingthismisconceptionintolegislation.

De facto pressure toward mandatory registration is already eroding choiceandcontrol AlthoughtheNDIShasnotformallymandatedregistrationacrossallsupportsfamiliesofparticipantswithcomplexneedsare experiencingincreasingpressuretouseonlyregisteredprovidersparticularly wherebehaviour supportplans(BSPs)orregulatedrestrictivepractices are involved.Thispressureresalready: - narrowingthepoolavailableworkersexcludingthespecialistswhocansafelysupportcomplexparticipantsforcingfamiliestowardlarge providerswhooftendeclinethigh-riskclientsundermininglegislated principlechoice controlTheCommitteeshouldnote thatpolicyintentoperationalrealityhavediverged The proposed amendments risk formalising a trendthatisalready harmingparticipants.

Impact on sole tradersandspecialist providers Theworkersmostcapableofsupporting participantswithseverebeaviours concernaresometimesoletradersorsmallspecialist providers.Theseindividualshave theskillwillingnesswork complex clientsbuild long-term, trusting relationships providecontinuityprevents crises and restrictive practicesHowevertheyalsoProvidersleast ableabsorb cost administrativeburdenregistration audits reporting. Proposed changes will drive many of these workers out sector entirely Thiswilldispropotionatelyharm participantstocomplex needs who alreadyparticipants with extremely thin markets

Economic implications :system relies unpaid care Unpaid carersexpandestimated$7 9billion worthcare annually significantly more than totalcostoftheNDIS.Familiesare backbone disability support Australia A legislative framework sidelines families favour bureaucratic oversight not only harmful to participantsit is economically unsustainable.Theproposedamendmentsriskincreasing NDIS expenditure by:

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

Submission 174

• forcing participants into more expensive service models
• increasing reliance on registered providers who may not accept complex clients
• triggering crises, hospitalisations, and restrictive practices when family-centred models are disrupted The Committee should consider whether the reforms align with the principles of efficiency, sustainability, and value for money.

Case studies demonstrating systemic risk

Case Study 1: Registration does not equal competence

Individuals with minimal experience can become registered providers by purchasing administrative support. These providers may then take on clients requiring restrictive practices. Meanwhile, families with decades of lived expertise are barred from using the same supports unless they operate through a registered entity. This is a structural inconsistency that undermines safety.

Case Study 2: Highly regulated systems can still fail

The Victorian Education Department—despite extensive oversight, governance, and reporting—was unable to keep our son safe. Thousands of incident reports and multiple layers of regulation did not prevent harm. Regulation protected the institution, not the child.

Case Study 3: Registered providers routinely decline complex clients

Between ages 8–10, approximately 40 registered services refused to support our son. The two that accepted him briefly withdrew due to complexity and risk. Only specialist sole traders—unregistered but highly skilled—were able to support him safely. Mandatory registration would eliminate these workers entirely. The examples demonstrate that registration is not proxy for safety*, and rigid regulatory frameworks can actively harm participants with complex needs.*

Family-centred models must be recognised in legislation

Alex’s current support model—a family-led multidisciplinary team consisting mostly of highly skilled solo traders—is the only arrangement that has ever kept him safe and eliminated the need for restrictive practices. However,the proposed legislative changes do not accommodate such models. They assume: -that registered entities should replace family involvement

• families cannot fulfil key safeguarding roles* These assumptions are evidence-based and reflect the lived reality of participants with profound disability.*

Risks if implemented without flexibility,

the proposed amendments will:* reduce choice and control -collapse thin markets for complex participants -increase NDIS costs -force participants into unsuitable service models -increase use of restrictive practices -undermine family-centric care

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

Submission 174

• prioritise bureaucratic protection over participant wellbeing These outcomes are inconsistent with the objects and principles of the NDIS Act.

Conclusion

Families are not NDIS providers but they are the most important protective structure for many participants with complex needs A legislative framework that sidelines families restricts access to specialist sole traders elevates bureaucratic compliance over real-world safety will harmthe very peopleth eNDIS existstosupport We urge th eCommitteeto ensurethat any amendments t oteNDSIAct:

• Preserve genuine choiceand control
• Enable flexible family-centred modelsof care
• Provide fit-for-purpose registration alternativesforsoletraders - Avoid embedding rigidcompliance structurestha ncrease riskanda ndcost The ND ISmust remain a systemt hat adapts toned ssof participantsnot one thats forcesparticipants to adaptton ed sofbureaucracy Wethank thee Committeeforc onsideringthis submission.