Submission 1897

Submission to the Senate Community Affairs Committee

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

Submitted by

I am , an individual and disability advocate expressing my own researched views, lived experience observations, and opinions regarding the proposed reforms to the National Disability Insurance Scheme (NDIS).

This submission raises concerns that the proposed reforms do not adequately address the actual structural causes of cost blowouts, fraud, service failures and participant dissatisfaction within the NDIS. Instead, many of the reforms appear directed toward restricting access, reducing supports, increasing surveillance and limiting participant rights, while failing to address systemic mismanagement, provider overcharging, procurement failures and governance issues within the NDIA itself.

The proposed reforms risk harming people with disabilities while leaving many of the underlying causes of financial waste untouched.

The Proposal to Push People off the NDIS Is Unrealistic and Dangerous

Concern

The reforms appear designed to narrow eligibility and shift many people away from the NDIS and back toward so-called “mainstream” or state-based systems.

This ignores the reality that those state systems largely no longer exist at the scale required to support people with disabilities.

Over the past decade, state governments transitioned large numbers of disability clients into the NDIS and subsequently shut down or drastically reduced their own disability services. Many specialist programs, accommodation supports, community access services and case management systems were dismantled.

If the Federal Government now intends to move people back into state systems, there is no functioning infrastructure capable of handling the influx.

Rebuilding those systems would take years and require:

Submission 1897

• new real estate and office infrastructure,
• workforce recruitment,
• specialist training,
• IT systems,
• governance structures,
• transport systems,
• housing capacity,
• regional service development,
• and entirely new operational frameworks. The disability workforce shortage already affects the NDIS itself. There are not enough trained and experienced workers available to suddenly recreate parallel state-run disability systems.

There is also significant risk that participants will:

• fall between systems,
• lose supports entirely,
• experience long delays,
• or become trapped in bureaucratic disputes about which agency is responsible. This creates foreseeable harm.

Recommendation

The Committee should recommend that:

• no participant be removed from the NDIS unless an equivalent alternative support system demonstrably exists and is operational,
• governments be required to prove service availability before shifting responsibilities,
• and participants retain continuity of supports during any transition process. The reforms should explicitly prohibit support gaps caused by intergovernmental disputes.

2. Requiring People to Exhaust Medical Treatment Is Cruel, Simplistic and Medically Naive

Concern

The proposed tightening of permanency and functional capacity tests appears to place greater emphasis on whether all treatment options have been explored or exhausted.

This approach fundamentally misunderstands disability.

Many disabilities:

• fluctuate,
• evolve over time,
• improve temporarily,
• deteriorate unpredictably

Submission 1897

• or respond partially to treatment while still requiring substantial supports. A person can receive treatment and still remain disabled.

For example:

• a person with chronic pain may undergo treatment for years while still requiring daily supports,
• a person with psychosocial disability may stabilise temporarily and later deteriorate,
• a person with neurological conditions may have periods of higher and lower functioning,
• new treatments may emerge years later,
• assistive technology may improve functionality without removing disability. The existence of treatment options does not mean a person no longer requires support.

Requiring people to continually prove they have exhausted all medical options creates:

• uncertainty,
• repeated reassessment,
• medical trauma,
• financial burden,
• and unrealistic expectations of “recovery”. It also creates a dangerous incentive for governments to deny support based on theoretical future treatment possibilities.

This is not person-centred disability support. It is an arbitrary gatekeeping mechanism.

Recommendation

The Committee should recommend that:

• access to the NDIS not depend on exhausting all medical treatment options,
• fluctuating and episodic disabilities be explicitly protected,
• and permanence be assessed based on ongoing support needs rather than speculative treatment possibilities. The legislation should acknowledge that treatment and disability support are not mutually exclusive.

3. Fraud Exists — But Participants Are Being Blamed for Systemic Failure

Concern

Fraud within the NDIS is a serious issue and should be addressed properly.

However, public commentary by NDIA leadership has increasingly framed participants themselves as the primary problem.

During Senate Estimates, NDIA Deputy CEO Mr Dardo described cases involving participants allegedly spending large sums of plan funding on:

Submission 1897

• alcohol,
• holidays,
• mortgage repayments,
• rent,
• rates,
• and unrelated purchases. He initially suggested this behaviour was occurring “in the thousands”, later reducing that estimate during questioning to “hundreds”, then “dozens”, and eventually “multiple people”.

Importantly, he also stated that providers were encouraging or pressuring participants into this conduct.

This raises a critical question:

If vulnerable participants are being manipulated by providers, facilitators or criminal operators, why are reforms targeting participant rights rather than the actors exploiting them?

Many participants:

• have cognitive disabilities,
• psychosocial disabilities,
• acquired brain injuries,
• intellectual disabilities,
• trauma histories,
• or communication barriers. These individuals are often highly vulnerable to coercion, manipulation and financial abuse.

The current reform approach risks collectively punishing people with disabilities for failures of regulation and enforcement by the NDIA and government.

Recommendation

The Committee should recommend:

• stronger criminal enforcement against fraudulent providers,
• specialist disability fraud taskforces,
• whistleblower protections,
• and targeted compliance against organised exploitation networks. Participants should not lose supports because governments failed to regulate providers effectively.

4. The NDIA’s Failure to Control Provider Overcharging Is a Major Driver of Overspending

Concern

According to NDIA data, approximately 95% of NDIS expenditure goes toward services.

Submission 1897

Yet widespread overcharging practices appear tolerated throughout the sector.

One example is cleaning services under Assistance with Daily Life supports.

Many cleaning providers:

• impose minimum two-hour charges,
• charge maximum travel costs,
• and bill for far longer than services actually delivered. Many participants report cleaners attending for less than an hour while charging for two.

I conducted a participant survey in which approximately 80% of respondents reported experiencing this issue.

If cleaning services account for a substantial portion of Assistance with Daily Life spending, this potentially represents billions in unnecessary expenditure over time.

Participants should not face funding cuts because:

• providers overcharge,
• the NDIA fails to regulate pricing,
• and enforcement mechanisms are ineffective. The NDIA appears more focused on restricting participant supports than on controlling systemic provider billing abuse.

Recommendation

The Committee should recommend:

• mandatory service-time verification systems,
• random provider audits,
• stricter travel charging rules,
• public transparency reporting for provider billing,
• and stronger penalties for systematic overcharging. Cost containment should focus first on provider waste before reducing participant supports.

5. NDIA Governance and Procurement Failures Must Be Examined

Concern

The reforms focus heavily on participant compliance while avoiding scrutiny of NDIA governance failures.

Serious concerns have been raised publicly regarding:

• procurement decisions,
• outsourcing arrangements,
• excessive consultancy spending,

Submission 1897

• and organisational mismanagement. Examples include:

• the engagement of expensive external systems and contractors,

• heavy reliance on outsourced staffing through companies such as Serco,

• high turnover among Local Area Coordinators through outsourced organisations,

• and repeated restructuring within the NDIA itself. There are also longstanding concerns regarding:

• poor workforce continuity,

• inadequate training,

• loss of institutional knowledge,

• and inconsistent participant decision-making. The NDIA cannot simultaneously argue that the scheme is unsustainable while failing to properly examine its own internal expenditure and governance structures.

Recommendation

The Committee should recommend:

• an independent audit of NDIA procurement and outsourcing,
• review of consultant and contractor spending,
• stronger public accountability measures,
• and reduced dependence on unstable outsourced staffing models.

6. Automated Decision-Making and AI Assessments Are Inappropriate for Disability Support

Concern

The reforms expand automated administrative decision-making and standardised assessment systems. Disability cannot be accurately assessed through blanket automation. Every person has:

• different strengths,
• different coping mechanisms,
• different environmental barriers,
• and different support needs. Two people with the same diagnosis may function entirely differently. A young blind person highly skilled with assistive technology may require different supports than another blind participant of the same age. Assessments already rely heavily on:

Submission 1897

• Occupational Therapist reports,
• specialist assessments,
• and medical evidence. Yet NDIA representatives have reportedly stated during Senate Estimates that staff often do not have time to fully review reports.

If existing human evidence is not being adequately considered, expanding automation risks worsening injustice rather than improving efficiency.

AI systems and standardised frameworks cannot replace nuanced human understanding of disability.

Recommendation

The Committee should recommend:

• prohibiting AI-driven support determinations,
• maintaining individualised human assessment processes,
• requiring full consideration of professional reports,
• and ensuring participants retain review and appeal rights against automated decisions.

7. Social and Community Supports Are Essential — Not Optional Extras

Concern

The reforms appear to target social and community participation supports as non-essential spending.

This misunderstands the role these supports play.

Community participation is not merely:

• arts and crafts,

• games,

• or recreation. These supports often assist people with disabilities to:

• attend medical appointments,

• maintain personal grooming,

• access the community,

• avoid social isolation,

• build confidence,

• and sustain mental health. Removing these supports risks:

• isolation,

• segregation,

• mental health deterioration,

• and long-term increases in healthcare costs.

Submission 1897

Keeping people connected to the community is preventative support.

It reduces crisis presentations and promotes independence.

Recommendation

The Committee should recommend:

• retaining strong protections for social and community participation supports,
• recognising community inclusion as essential support,
• and preventing overly narrow interpretations of “reasonable and necessary”.

8. Representation and Governance Within the Disability Sector Requires Reform

Concern

Successive governments have appointed individuals to the NDIA Board and advisory bodies without direct democratic accountability to the disability community.

Many participants feel they do not have meaningful representation.

People with disabilities should not merely be consulted after decisions are made. They should have genuine influence over governance structures affecting their lives.

Recommendation

The Committee should recommend:

• stronger participant representation requirements,
• transparent appointment processes,
• and mechanisms allowing people with disabilities greater influence over NDIA governance and advisory structures.

9. The Reforms Target Symptoms Rather Than Causes

Concern

The proposed reforms largely frame rising costs as a consequence of participant access and participant behaviour.

This ignores broader structural failures including:

• provider overcharging,

Submission 1897

• outsourcing inefficiencies,

• procurement waste,

• staffing instability,

• inadequate regulation,

• and poor NDIA administration. The reforms risk:

• reducing supports,

• increasing bureaucracy,

• expanding surveillance,

• and restricting participant rights, while failing to address many of the actual drivers of waste and inefficiency. Participants with disabilities should not bear responsibility for failures of government administration.

Recommendation

The Committee should recommend:

• a full independent review into NDIA governance and operational management,
• prioritising provider regulation before participant restrictions,
• and redesigning reforms around participant wellbeing rather than fiscal containment alone.

Conclusion

The NDIS absolutely requires improvement, stronger oversight and better financial management.

However, these reforms risk harming people with disabilities while failing to properly address:

• systemic provider abuse,

• NDIA governance failures,

• outsourcing inefficiencies,

• procurement waste,

• and poor regulatory enforcement. The sustainability of the NDIS will not be achieved by:

• removing vulnerable people,

• limiting supports,

• automating assessments,

• or forcing participants into non-existent state systems.True sustainability requires:

• competent governance,

• effective regulation,

• participant-centred planning,

• and accountability for those managing the scheme itself.People with disabilities should not be punished for the failures of governments and administrators to properly manage the system.