NDIA Accountability Project

Concerns regarding reforms to eligibility, planning, reassessment, evidentiary requirements and access to supports

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Submission 1898

Submission to the Senate Community Affairs Legislation Committee

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

Submitted by

Central West NSW

Declaration

I make this submission in my personal capacity as a parent, carer and registered psychologist. The views expressed are my own and do not represent my employer, any professional association, advocacy organisation or any other affiliated entity. This submission draws on my lived experience as the parent of a young person with disability and my professional experience working with children, adolescents and adults with disability in regional New South Wales.

Introduction

I support the continued operation of a sustainable, accountable and high-quality National Disability Insurance Scheme (NDIS). I also support measures to address fraud, improve consistency, strengthen safeguards and ensure that public resources are administered responsibly.

However, I am concerned that the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 proposes substantial changes to eligibility, planning, reassessment, evidentiary requirements and access to supports without sufficient publicly available evidence that these measures will improve long-term outcomes for people with disability, their families and Australia as a whole.

My concern is not with reform itself. Rather, it is with reforms of this scale proceeding without robust evidence that they are likely to achieve their stated objectives and improve outcomes over time.

The NDIS was created as an insurance-based scheme to promote participation, independence, inclusion and quality of life for Australians with disability.¹ Reforms should therefore be assessed not only by their effect on spending, but also by how they are likely to affect:

  • participant wellbeing;
  • educational participation;
  • employment outcomes;
  • community participation;
  • housing stability;
  • health outcomes;
  • family functioning;
  • carer wellbeing; and
  • long-term social and economic outcomes.

Submission 1898

The Central Question: How Will These Reforms Improve Long-Term Outcomes?

The Government has stated that these reforms are necessary to secure the future sustainability of the NDIS and improve consistency and accountability.  Financial sustainability is important. However, the NDIS was established as a lifetime insurance scheme, informed by actuarial principles and intended to improve long-term outcomes while reducing future societal costs.  ³

The central question is not merely whether expenditure growth will be moderated, but whether the mechanisms proposed in this Bill will improve long-term outcomes for participants, families and Australian society.

To date, there appears to be limited publicly available evidence demonstrating how these reforms are expected to improve the following outcomes:

  • participant wellbeing;
  • educational participation;
  • employment outcomes;
  • community participation;
  • housing stability;
  • mental health outcomes;
  • family functioning;
  • carer wellbeing; or
  • long-term economic contribution.

There also appears to be limited publicly available analysis of the likely effects of these reforms on other systems, including:

  • health;
  • mental health;
  • education;
  • housing;
  • welfare;
  • child protection; and
  • justice systems.

A reduction in NDIS expenditure is not necessarily a reduction in societal cost. It may instead represent the transfer of cost from one system, sector or family to another.

Given the scale of the proposed reforms, stronger longitudinal evidence should be provided to show how these changes are expected to improve participant outcomes and reduce overall societal costs over time. This is especially important given that the NDIS Act was enacted to support independence, social and economic participation, choice and control, and to give effect to Australia’s obligations under the Convention on the Rights of Persons with Disabilities.  ¹⁶

As Parliament considers these reforms, it is appropriate to ask not only whether they will restrain expenditure growth, but whether they remain consistent with the objectives and principles of the NDIS Act and with the long-term outcomes the Scheme was designed to achieve.

Submission 1898

Disability Support Should Not Depend on Exhausting Treatment Options One of my principal concerns is the increasing expectation that participants demonstrate they have pursued treatment options before receiving disability supports. As a psychologist, I regularly work with people whose functioning improves with intervention. However, improvement does not negate disability or remove the need for support.

Many people benefit from therapy, rehabilitation, medication or other interventions while continuing to experience substantial and enduring disability-related impairment. Disability support and treatment are not interchangeable. Both may be necessary simultaneously.

The reforms raise important questions:

  • What constitutes a reasonable treatment pathway?
  • How much treatment is enough?
  • What if treatment improves functioning but disability remains?
  • What if treatment is unavailable?
  • What if waiting periods are years long?
  • What if treatment is unaffordable?
  • What if the individual lives in a region where services are simply unavailable?

Participants should not be left between systems, required to continue pursuing treatment while disability supports remain inaccessible, delayed or uncertain. A person should not have to prove that every treatment avenue has been exhausted before receiving the supports necessary to live safely and participate fully.

Mainstream Systems Cannot Be Assumed to Meet Disability Needs The proposed reforms place greater emphasis on whether supports may be available through health, education or other mainstream systems. ² In principle, disability systems should not duplicate services available elsewhere. However, this principle assumes that alternative systems are adequately funded, accessible and responsive.

Many Australians already experience significant barriers accessing mainstream services. These barriers include:

  • workforce shortages;
  • lengthy waiting periods;
  • affordability constraints;
  • geographical limitations;
  • fragmented service systems; and
  • inconsistent availability.

Availability on paper is not genuine access in practice. Participants should not lose disability supports because another system could theoretically provide assistance that is unavailable in reality. Without substantial investment in mainstream and foundational supports, there is a real risk that people with disability will fall between systems, with costs and consequences displaced elsewhere.

Submission 1898

Regional and Rural Australians Face Additional Disadvantage

Many assumptions underpinning the proposed reforms appear to rely upon timely access to treatment, specialist services and alternative support pathways.

In regional and rural Australia, these assumptions often do not reflect reality. Families may travel several hours to access specialist assessment, therapy or medical services. My family, for example, regularly travels four hours each way for specialist assessment and treatment. Provider choice is limited or non-existent, waiting periods are longer than in metropolitan areas, and workforce shortages are common.

Reforms that assume timely access to alternative services are likely to disproportionately disadvantage rural and regional Australians. Any implementation framework should therefore expressly assess the impact of these reforms on regional, rural and remote communities before access pathways are altered.

Maintaining Function Is a Legitimate Outcome

Much discussion of disability support focuses on improvement, recovery or increasing independence. However, for many participants, the primary purpose of support is to maintain function and prevent deterioration. This is particularly relevant for people living with physical disabilities, chronic illnesses, degenerative conditions, intellectual disability, autism, psychosocial disability and acquired disabilities.

Appropriate supports may prevent:

  • hospitalisation;
  • mental health deterioration;
  • family breakdown;
  • social isolation;
  • educational disengagement;
  • loss of employment; and
  • premature institutionalisation.

A participant whose functioning remains stable may reflect a successful outcome rather than a lack of progress. In many cases, maintaining stability is precisely what prevents more intensive and costly interventions later.

Future policy should expressly recognise the maintenance of function and the prevention of deterioration as legitimate and valuable outcomes. More broadly, policy success should not be measured primarily by reductions in support expenditure, but by the extent to which deterioration is prevented, functioning is maintained and future costs across health, education, housing and social support systems are avoided.

Existing Participants Face Increased Uncertainty

The proposed reforms affect not only future participants but also many current participants through reassessment, revised planning approaches and altered support frameworks.

Submission 1898

Many participants have organised their lives around existing supports. Families have made decisions about employment, housing, education, transport and care arrangements on that basis. Increased uncertainty about future eligibility and support levels may itself create instability, undermine planning and erode confidence in the Scheme.

The Scheme should provide certainty wherever possible, particularly for individuals living with permanent and lifelong disabilities.

Clinical Expertise Should Continue to Inform Decision-Making The reforms place greater emphasis on peer-reviewed evidence and standardised approaches to support determination and planning. Evidence-based practice is important and should remain central to decision-making.

However, disability populations are heterogeneous and individual needs vary considerably. Some interventions may not have extensive research evidence despite demonstrating meaningful participant-specific benefits. Clinical judgement, participant experience and functional outcomes must continue to be considered alongside traditional evidence hierarchies.

A system that privileges generalised evidence while discounting participant-specific outcomes risks overlooking genuine need and diminishing responsiveness to individual circumstances.

Families and Carers Cannot Absorb Unlimited Additional Responsibility The reforms strengthen consideration of informal supports and family involvement. Families already provide substantial unpaid labour, including:

  • care coordination;
  • advocacy;
  • supervision;
  • emotional support;
  • transport;
  • appointment management;
  • crisis intervention; and
  • assistance with daily living.

Many carers reduce their workforce participation and experience significant impacts on their own wellbeing. In my own case, I can work only reduced hours to support my child. This places pressure on my family and affects the broader community, contributing to workforce shortages, longer waitlists and reduced availability of a specialised service.

Reducing funded supports does not remove need; it transfers responsibility elsewhere. A sustainable NDIS must therefore consider not only the sustainability of government expenditure, but also the sustainability of families and carers who already shoulder substantial responsibility.

Submission 1898

Recommendations

I therefore urge the Committee to: - Require robust evidence that the reforms will improve long-term participant outcomes. - Require independent longitudinal evaluation of impacts on wellbeing, education, employment, family functioning, health service use and whole-of-government costs. - Publish outcome measures and evaluation frameworks before major implementation. - Assess the reforms against whole-of-government costs, not NDIS expenditure alone. - Ensure disability support is not contingent on exhausting treatment pathways. - Require evidence that mainstream and foundational supports are genuinely accessible before reducing disability supports. - Assess impacts on regional, rural and remote communities before implementation. - Recognise maintenance of function and prevention of deterioration as legitimate support outcomes. - Preserve meaningful weight for clinical expertise, participant experience and individual circumstances.

  • Assess the reforms’ impact on families and unpaid carers.
  • Assess all reforms against the objects and principles of the NDIS Act and Australia’s obligations under the Convention on the Rights of Persons with Disabilities.

Conclusion

The NDIS was established because Australia recognised that disability support should not depend on charity, geography, family capacity or personal financial resources. The Scheme reflects a national commitment to participation, inclusion, dignity and equal opportunity.

I support evidence-based reform, accountability and sustainability. However, sustainability should not be assessed solely by reference to expenditure growth.

The ultimate question is whether these reforms will improve the lives of Australians with disability while strengthening Australia’s long-term social and economic future.

At present, I remain unconvinced that sufficient evidence has been presented to demonstrate that the specific reforms proposed in this Bill will achieve those outcomes.

I respectfully urge the Committee to ensure that any future reforms remain guided by evidence, transparency, participant outcomes, disability expertise and long-term societal benefit.

Thank you for the opportunity to provide this submission and for considering the perspectives of people with disability, families, carers and frontline professionals in evaluating these proposed reforms.

Sincerely,

Submission 1898

References

  • National Disability Insurance Scheme Act 2013 (Cth), particularly ss 3–4 (Objects and General Principles).
  • National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 and Explanatory Memorandum.
  • National Disability Insurance Agency. Insurance Principles and Annual Financial Sustainability Reports.
  • Australian Government Department of Health and Aged Care. NDIS Legislation Changes and Securing the NDIS for Future Generations reform materials.
  • Independent Review of the NDIS (2023), Working Together to Deliver the NDIS.
  • United Nations Convention on the Rights of Persons with Disabilities.
  • Attorney-General’s Department. Rights of People with Disability – Public Sector Guidance.