NDIA Accountability Project

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Concerns regarding funding reductions across support categories (Individual advocacy)

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Submission on the National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

Belong & Disability Rights and Culture

Table of contents

  • Summary: page number (to be determined)
  • About Disability Rights and Culture and Belong: page number (to be determined)
  • Provisions of the Bill addressed by this submission: page number (to be determined)

Detailed comments by Bill schedule and part:

1. Schedule 1 - Access and Planning Measures (

to be continued):

Parts related content with page numbers.
2. Schedule 2 - Fraud Measures

page number, …

National Disability Insurance Scheme Amendment

Submission 19 - Supplementary Submission

Summary This submission raises serious concerns about the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 and the risks it poses to disabled people, families, carers, disabled people’s organizations and the long-term integrity of the NDIS.

This submission is written from the perspective of disabled people connected through Belong, Disability Rights and Culture’s disability-led community. Belong exists because disabled people need more than services: we need connection, safety, culture, peer support, accessible information and genuine opportunities to participate in community life.The NDIS requires reform and stronger safeguards against fraud, exploitation, and poor-quality services. However, reform must strengthen disabled people’s rights, safety and inclusion.It must not reduce essential supports before replacement services in mainstream foundational or community systems are available, accessible, adequately funded and independently shown to work.This submission particularly raises concerns about:● broad powers to reduce funding across support categories including social civic and community participation capacity building daily activities;● reductions to community participation and home-based supports that are essential to safety, inclusion independent living; ● narrow functional assessments impairment-link requirements automated rules based decision-making;● risks autistic people with ADHD psychosocial disabilities chronic illness fluctuating episodic disability;● cost-shifting schools hospitals mental health services housing child protection state territory systems;● threats self-management direct employment trusted support relationships participant choice control;● suspension loss-of-support for participants considered ‘not contactable’; ● lack-genuine-co-design transparent-modelling-and-accessible-consultation. The Bill should be withdrawn redesigned partnership between disabled people their representative organizations consistent principle nothing-us-without-us If the Bill proceeds inquiry timeframe extended allow proper consultation modelling human-rights-analysis public scrutiny

About Disability Rights Culture Belong DisablityRightsandCulture DRC previously DisabilityResourcesCentre is a community-building campaigning advocacy organization. DRC radically inclusive Disabled People’s Organization brings together people culture identities experiences.Belong free run by members Australia culture gender identity age disability offers spaces where safe unmask themselves heard others understand lived experience.

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

Submission 19 - Supplementary Submission

Belong connects people through online groups, in-person events, Discord, WhatsApp chats, emails and newsletters. Belong members include people with physical disability, learning disability, chronic illness, prolonged physical or mental illness, mental health conditions, aquired brain injury, speech and communication conditions, sensory disability, nurodivergence, self-identifying disabled people and people in the process of diagnosis.

Belong’s perspective is highly relevant to this Bill. The Bill’s proposed changes to access, functional capacity, community participation, plan reassessment, plan suspension, provider arrangements and new framework planning will be experienced by disabled people not just as administrative changes but also affect their ability to belong, connect safely maintain relationships participate fully within communities exercise choice control over decisions made on behalf them.

Provisions addressed

The Senate inquiry has asked that submissions directly address provisions outlined below:

Bill provision
Schedule I Parts:38 & 9
Schedul eI Part s25&6
Sch edule IParts46
Scheduled Part7
.Part1456
Sc hedule 3Parts12
S chdule 4
S chedule S

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

Submission 19 - Supplementary Submission

Detailed comments by Bill schedule and part

Schedule 1 - Access and Planning Measures

Sections covering functional capacity requirements:

These provisions raise serious concerns for people whose disability is complex, fluctuating, episodic, poorly understood, masked or linked to multiple impairments. Psychosocial disability, autism, ADHD, chronic illness, many neurological conditions cannot always be understood through a narrow one-off assessment. The proposed stronger link between funded support and an impairment may appear administratively clear but risks artificial separation in real life due overlapping impacts from psychosocial, neurodevelopmental cognitive physical health sensory impairments A support can prevent crisis reduce distress maintain hygiene enable access family stability simultaneously The approach also risky if interpreted as requiring exhaust treatment before receiving disability support Treatment therapy medication school adjustments need occur together People should lose access denied because still being attempted partially alleviated mainstream system theoretically responsible practically inaccessible Part’s focus on eligibility based other service systems creates cost-shifting risk Schools mental services housing child protection workers compensation not consistently accessible inclusive adequately funded Disabled children adults should not lose NDIS support governments assume another system meet needs yet equipped For children especially autistic with ADHD those with psychosocial occupational psychology speech behaviour supports keep connected families schools community In practice under-resourced inconsistent providing reasonable Adjustments allied help understand their child’s communicate exclude burnout crisis ### Parts 4 &6 - Support Determinations Reasonable Necessary Supports Part particularly concerning enables Commonwealth Minister make determinations reducing funding groups of social civic capacity building daily activities These are optional extras

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

Submission 19 - Supplementary Submission

They are often the practical supports that allow disabled people to get out of bed, eat, wash, attend appointments, participate in community life, stay safe at home and avoid crisis. For Belong members, community participation is not simply recreation. It is connection, peer csupport, safety, access to information, a pathway into advocacy, a place to be understood, annd a safeguard against isolation. Social and community participation reduces the risk of abuse, neglect, violence, and mental health deterioration because isolated people are often less visible and less able to seek help. Reducing these supports risks: increasedisolationanddisconnection; worseningphysicalandanmentalhealth; familycarerburnout;hospitalisationandriskintervention;earlierentryintosupportedaccommodationorresidentialcare;lossofskillsandcommunityrelationships;anincreasedpressureonhealtheducationchildprotectionhousingandenentalhealthisystems. Part’sreasonableandsufficientchangesshouldnotshifttheNDISfromanindividualisedrights-basedschemeintoaschemedominatedbyaggregateexpenditurecontrols.Sustainabilitymattersbutitmustnotebeusedtojustifyblanketreductionsthatignoreindividuallrisk,safetycommunicationculturetraumaruralityfamilycircumstancesorthelackofaccessiblealternatives.TheBillshouldequirethathnosupportdeterminationreduceormovesupportsunlessParliamentandthedisabilitycommunitiescanseethemodelling,thehumanrightsanalysisthestatedrules,theimpactoneightriskgroupsandevidencetherplacementservicesarealreadyavailableandaaccessable13Parts25limitsunscheduledplanreasessmentsandplannerewalTheBilproposestightenecriteriaforunscheduledplanreaassessmentsandoointroducedlegistlatedenddatesWhileclearprocessesmaybefulfulwhiletherestrictionsriskyappingpeopleinadequateplanswhentheircirecumstancechangequicklyorthentheircurrentwasunsafe.Disabledpeoplemayneedurgentassessmentinformalsupporscollapse,housebecomesunsafeachildisecludedschoolapersonexperiencefamiliviolenceparticulardischargedhospitalpsychosocialdisabilitescalatescarerbecomeunwellorfunctionalcapacitychangesbecauseburnoutchronicillnessthesesecondsoflifealsotheendrolloversnoncarryoverofunspentfundsmaypunishparticipantsunderspendreasonoutsidecontrolincludingprovidershortagesthinmarketsinaccessibleservices,hospitalisationhomelessness,familyviolenceadministrativedelaysdifficultyfindingculturallysafetrauma-informedworkersortheneedingtimebuildtrustsupportworkerPlanrenewalprocesmustincludeaccessiblenoticeadvocacyaccehumanreviewcapactoresponsocrisissafeguardsopleasedoesloseupportmarketfailureadminstrativedelay

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

Submission 19 - Supplementary Submission

Part 7: Plan Suspension and “Not Contactable” Provisions

Part 7 creates serious safeguarding risks by allowing a plan to be suspended when the NDIA has made reasonable attempts to contact a participant but hasn’t received an adequate response. It also allows revocation after suspension if non-contact continues over time, specifically targeting those most at risk:

  • unable due to communication support issues; cognitive/Intellectual/Psychosocial disabilities; hospitalized/transitional from hospitals; housing instability/homelessness; family/violence/coercive control victims; isolated services/community members; lack reliable phone/internet/mail/digital access; trauma/anxiety/executive dysfunction/burnout survivors; dependent on unsafe nominees/carers/providers; or culturally diverse communities with inaccessible methods.

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

Submission 19 - Supplementary Submission

Schedule 3 - Governance Arrangements

Schedule 3 includes pricing governance and automation of administrative action. These provisions require strong safeguards because pricing decisions and automated processes can have major practical effects on the availability, quality and safety of supports. Pricing decisions must be transparent and must include meaningful engagement with disabled people, workers, providers, families and representative organisations. Price reductions or indexation decisions can reduce workforce stability, increase staff turnover, push providers out of thin markets, and make it harder for participants to find safe and skilled workers. Automated administrative action also raises serious concerns. Even if automation is described as administrative, automated processes can still shape who is paid, when claims are processed, what evidence is accepted, whether a matter is escalated, and whether a participant is left without support. Rigid systems cannot replace human judgment in a scheme that deals with complex disability, communication needs, digital exclusion, and crisis situations. Any use of automation must include: clear limits on what can be automated; no automated suspension, reduction, debt or access decision without human review;accessible reasons that explain the decision in plain language; public information about the rules, inputs and error-checking processes used; easy correction of errors; review and appeal rights before harm occurs;andindependent monitoring for discriminatory or unsafe outcomes.

Schedule 4 - New Framework Planning

Schedule 4 makes amendments to support new framework planning, including support needs assessment and budget method rules. This is one of the most significant parts of the reform agenda because it will determine how disabled people’s support needs are translated into funding. A support needs assessment must be a whole-person assessment. It must not reduce disabled people to a score, category or algorithmic output. It must capture real life, including fluctuating disability, masking, burnout, psychosocial distress, sensory needs, communication needs,family circumstances,housing safety,rurality,thin markets,culture,traumand cumulative barriers across systems.Rulesaboutwhatanassessormustandmustnotconsidershouldbecodedesignedandpubliclyavailablebeforecommencement.Participantsmustbeabletoprovideevidencefromtreatingpractitionersalliedhealthprofessionalsadvocatesfamilysupportworkersandpeoplewhoknowtheirday-to-dayfunctioning.Assessorsmustbetrainedindisabilityrightstraumacommunicationaccessculturalsafetypsychososialdisabilitynurodivergence,andintersectionaldiscrimination.Budgetmethodrulesmustbetransparent.Participantsandadvocatessenedtounderstandhowassessmentinformationiscorvertedtosupporttypesandfundinglevels.Withoutransparency,newframeworkplanningrisksbecomingahiddenmechanismforbudgetreductionratherthanafairandrighbasedplanningsystem.

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

Submission 19 - Supplementary Submission

Transition to new framework planning should not occur until the assessment tool, rules, review pathways, advocacy supports, accessible information, workforce capacity and human groups have been tested with disabled people and independently evaluated.

Schedule 5 - Transitional matters

Transitional provisions must protect people from harm during implementation. Major reforms should not be switched on before participants, families, advocates, workers, providers, states and territories understand the rules and replacement systems ready. No participant should lose support experience a significant reduction move into a new framework plan denied access because assumed supports main stream foundational systems unless those supports fully funded readily available accessible culture safe disability competent independent prove relevant need.The transition include: available direct funding supported decision making public modelling staged implementation independent evaluation transparent complaints data enforceable commitment no person left without essential support during this period.Human rights concernsThe NDIS created Australia’s obligations under United Nations Convention Rights Persons Disabilities UNCRPD.Bill risks undermining:Article living community inclusion equality non discrimination freedom violence abuse neglect adequate standard of living social protection consultation active involvement disabled people.Reforms place emphasis expenditure control administrative efficiency leaving many safeguards later rules instruments operational systems.Disabled accept risk unable assess practical impact reform.A rights based Bill put safeguard transparency review right advocate access co design primary legislation rather than leave them to later implement.R# Recommendations1 With draw recommence genuine partnership disabled people family carer worker Disabled People Organisations2 If proceed extend inquiry process allow meaningful consultation engagement independent modeling human rights analysis scrutiny3 Release all models draft rules before proceeding including reduced access fund autistic ADHD psychosocial children families self management participation cost shifting workforce market impacts automated decision-making4 Do not reduce remove through Schedule 1 unless equivalent already available accessible funded culturally safe independently proven mainstream foundational or community system

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

Submission 19 - Supplementary Submission

  • Protect access to occupational therapy, psychology, speech therapy, behaviour support, support coordination, community participation, in-home supports and other capacity- building supports that prevent crisis and maintain inclusion.
  • Amend Schedule 1 to ensure assessments properly capture fluctuating disability, psychosocial disability, sensory needs, communication, executive functioning, masking, burnout, trauma, chronic illness and the interaction between multiple impairments.
  • Remove or substantially amend Schedule 1 plan suspension and revocation provisions relating to participants being “not contactable”, including strong safeguarding protections, outreach obligations, advocacy access, supported decision-making and human review.
  • Ensure Schedule 2 fraud and integrity measures protect participants from exploitation\non undermining self-management, direct employment, trusted support relationships,, flexiblesupportsor choiceandcontrol.
  • Ensure recordkeepingshorterclaimande debtprovisionsincludeaccessibleeducation,supported compliance,vulnerability safeguardsandexemptionswheredisability,crisisexploitationorp rovider misconduct affectscompliance. StrengthenSchedule3safeguardsforautomationincludingmandatoryhumanreviewaccessiblereasons,t ransparencyaboutrulesandinputs ,correctionpathways,reviewrightsandi ndependentmonitoringfordiscriminatoryimpacts EnsureSchedul epricingdecisionsaretransparentanded informedbydisabledpeopleworkersprovidersandrepre sentativeorganisationswithspecificconsiderationofthin marketsworkforce stabilityandsafety Do not commence Schedu le4newframeworkplanninguntilthesupportneeds assessment,budgetmethod rules,evidence rule s,revi ew pathwaysandsafeguardshavebeenco-designed,published,tested with disabled people independently evaluated. Createstrongprotectionsagainstcost-shiftingbetweentheNDISandmainstream systems,includingarequirementthatnosupportbewithdrawandon thebasis ofanother systemunless thatsystem isactuallyavailableanda ccessibletotheperson. Guarantee accessible review and appeal rights before any participant losessupport, experiencesasignificant reduction,is moved to a new framework plan,hasa plansuspendedorison ineligible. Ensureall reforms are co-designedin partnership disabled peopletheir representative organisationsconsistent ithoprinciple“nothing about us withoutus” .

Conclusion The NDIS requires reformbutreformmust makethe Scheme fairer,safe rmore transparent\ando more rightsbased. This Bill creates significant risks for disabled peopl by reducing supports anda increasing administrative powersbeforereplacement syste msandsafeguards ar fully operational.For Belong,the central issue isnotonlyfunding.Itisthetherdisabledpeoplecanlives afely remain connectedparticipateincommunitybuilddisability culturereceivessupp ortfrom trustedpeop leandexerc isechoicecontrolover their lives.The Government should withdraw thisBillandre design thereformsingenu inouspartnershipwith disabled peopleandtheadvocacy community.IfthisBil lproceeds,Parliamentshouldnot passitwithoutstrongersafeguardsindependentscrutinytransparentmodellingaccessible revi ewrightsandmeaningfulconsultation with the peopletheScheme istdesignedtosupport.

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

Submission 19 - Supplementary Submission

Key sources used to map the Bill provisions