Concerns regarding restrictive access and inadequate co-design for children with complex disabilities (Family or carer experience)

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

Submission 1824

Inquiry into the National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

Submitted by: redacted Version: Version - Formal Policy Submission

Note on AI Use: The submission was prepared using an assistive technology to manage ADHD symptoms. I am responsible for its accuracy as it reflects my own ideas but uses tools that help me communicate clearly despite dyslexia or other challenges related to writing. This is a reflection about living invisibly in society while managing these conditions independently, as I navigate life fully participating civicly professionally often without formal support. My use here shows how adaptive strategies are needed when dealing invisible disabilities like mine.

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

Submission 1824

  • Delay passage of the Bill until genuine co-design consultation has occurred with the disability community, including First Nations, rural, and complex-needs representatives.

Concern 2: Excessive Ministerial Powers Without Adequate Oversight

The Bill grants unprecedented discretionary powers to the Minister through legislative rules rather than primary legislation. Critical matters left undefined in the Bill itself include definitions of NDIS-fundable supports, assessment tools, eligibility criteria, funding methodologies, appeal pathways, and transitional protections. These are not administrative details — they are central to the rights, autonomy, and quality of life of disabled Australians. Families are being asked to accept significant reform while the substantive rules governing that reform remain undefined. This is not a reasonable position to place the disability community in.

  • Ensure all key eligibility criteria, assessment processes, and appeal pathways are defined in primary legislation rather than delegated to ministerial rules.
  • Introduce stronger parliamentary oversight mechanisms and transparency requirements for ministerial rule-making under this legislation.
  • Publish proposed assessment tools and funding methodologies for public consultation before implementation.

Concern 3: Restricting Access Without Addressing Systemic Inefficiency

I acknowledge and support the principle that the NDIS must remain financially sustainable. However, this Bill appears to focus on reducing participant access rather than addressing systemic inefficiencies that drive scheme costs. Families routinely observe significant waste through excessive bureaucracy, duplicated assessments for permanent disabilities, inconsistent planning decisions, poor inter-system coordination, delayed plan approvals, and long review and appeal processes. In my own experience, we have submitted extensive evidence from paediatricians occupational therapists psychologists behaviour support practitioners play therapists—and continue to face uncertainty about whether essential supports will remain accessible The system creates additional administrative burden and emotional trauma for families already under extreme pressure.

- Prioritise reform of administrative inefficiency before reducing participant access including eliminating duplicated assessments reduce unnecessary reassessments

to eliminate duplicate assessmen ts reduc ing unnec essary reas sessment s of per man ent dis abilitie s an d im pr oving pl annin g con sist ency . - Ensure review and appeals processes remain accessible transparent timely.

Concern 4: Risks to Children With Complex and Invisible Disabilities I am particularly concerned about children with invisible fluctuating or psychosocial disabilities includi ng autistic chil ren wit h complex behav iour al a nd senso ry suppo rt nee ds Ch ildren like m y da ugh ter do n ot fit neatly into simplistic functional assessment s A child may appear verbally capable academically bright while simultaneously being unable attend redacted

Senate Community Affairs Committee Submission | | Page 2 of 4

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

Submission 1824

school consistently, requiring constant supervision to prevent self-injury or absconding, and needing extensive co-regulation from caregivers throughout every part of the day.

The proposed use of functional assessment tools such as the I-CAN is not inherently inappropriate — but I have serious concerns about how they may be administered. The I- CAN is a complex clinical tool currentl y requirin g specific professional traini tg.Any proposalto allow it tbe administratedby unqualifiedor minimally trained individualsas acost-saving measure risks producing inaccurate assessments,particularlyfor individuallswith maskingbehaviours,fuctuatingcapacity, orcomplexneurodivergentpresentati ons.

If eligibility criteria become overly narrow,many childrenwit substantialfunctional impairmentsmay lose access toe ssential supports.This wouldnot reducen eed—itwould shift costsand crises tobospitals ,mental health systems,educationsystems,chil dprotection,emergency services,and familiesalready at breaking point .

  • Ensure allNDISassessmentsare conductedordirectly overseen by appropriately qualifiedalliedhealthprofessionals with relevantclinicalandan func tionalexpertise.- Adopt neuroaffirm ing an dt rau ma-inforn ed approaches when assessing autisticchildrenan din dividuals wit h psychosocial disability -Ensureassessment frameworks are designed to capture fluctuating and context-dependentfunc ion al impairment,n ot just observabledeficitsat asinglepoint in time

Concern 5: Workforce Gaps and Community Participation Supports The Bill does not adequately address one of the most significant barriers participants face: the inability accesssupports evenwhen fundingexists. In many areas,t herapists carry extensive waitlists,b ehaviour support practitioners arendifficultto acces s,support workers lack training for complex neu rodiver gent presentations,a ndregional fam iliesface severe shortages.Reducing participant supports without first addressing these structural gaps risks worsening outcomes while failing t o achieve meaningful sustainability.

Community participation suppor ts a re frequently mischaracterisedas optional extras.For childrenlikemy daughtertheya renot.Theyarethow disabledch i lden learntosafelyexistintheworld.Theyaret he wheretheskillsbuiltthroughtherapy—emotional regulation,communication , sensory tolerance—are appliedinear environmentswith peers .Theyarethefoundationsoffutureparticipationineducation employment relationships,and community life.Withoutthem therapyriskstbecoming disconnectedfrom functional outcom esand families becomeincreasingly isolated My older child is evidenceo f what timely an dappropriate su pport canachieve.W ith early NDISsupportheisnowthriving acad emically sociallyan de m otionallyways that once seemedimpossible.That progresswas only possiblebecause wecould access helpbefore crisispoint andwithout constant fearwhetherwe could sustain itprivately.I worry howeverthat his current capabilities maymeanheno longerqualifiesfor thesupports th at aremakingt hatprogresspossib le.Hiss disabilityfluctuatesands hcurrentcapacityisanotaguarantee ofhis future capacity. Having tore- qualif y throughlengthyprocessesrisks him losingthe potentialhes hasworkedsohardto build.Thisist whyI am soconcerned about reforms thatcreate further barriers forfamiliescurrently in then positionw eonce were.

Senate Community Affairs Committee Submission | redacted | Page3 o fa4

Concern 6: The Invisible Cost of Unsupported Caregiving

My daughter currently requires near-constant supervision, extensive emotional co-regulation, environmental modification, reduced school attendance, multiple therapeutic supports, and tensive parental involvement across all settings. These demands significantly impact employment, finances, mental health, relationships, and the wellbeing of siblings. What often missing from policy discussions is the reality of what daily life looks like for families in this position. When governments frame disability supports primarily through the lens of financial burden, families feel invisible.The economic contribution of unpaid carers — particularly mothers, many of whom leave the workforce entirely—rarely acknowledged. NDIS simply about funding therapies.For many families.it difference between sustainabilityand collapse.

12.Formally recognise essential role of unpaid carers within framework assess risks reforms increase without corresponding support. 13.Ensure impacts on well-being and participation are included cost-benefit analysis underpinning these reforms.

Conclusion

I support reform that genuinely strengthens long-term sustainabilty.But cannot come at expense disabled people theirfamilies.True reform collaboration transparency evidence-based investment systems actually work.I would ask Committee hold onto one fundamental truth changing who can access NDIS or what they may receive does not make disabled people or their needs disappear.What Australia seeing though visibility creation need alone.That visibility confronting when viewed financiallyalone.Disabled Australians accounting problems to be reduced.They members community responsibility government making theminvisible again but find sustainable fair humane ways include them.Disability deserves developed with themnot forthank you considering this submission.