National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1952
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: Darrell Meredith Role: Community Neurorehabilitation Clinician Experience: Over 35 years of community-based practice in acquired brain injury rehabilitation Date: 1 June 2026
Preamble I write as a clinician with over 35 years of practice in community neurorehabilitation, working directly with people living with acquired brain injury (ABI) and other neurological conditions. My work sits at the intersection of disability practice, health, and social welfare — a position that informs each of the concerns I raise in this submission. My perspective on the NDIS is grounded in direct clinical practice: I have supported a number of NDIS participants over many years, and it is from that sustained, ground-level engagement with the scheme that I write.
This submission addresses three areas of the proposed Bill: the proposed provider registration framework, the 50 per cent reduction in social and community participation budgets, and the adequacy of proposed changes when considered against the lived cognitive and functional realities of people with ABI.
- Provider Registration: Competence, Not Professional Hierarchy The Bill’s movement toward expanded mandatory provider registration is, in principle, welcome. Protecting vulnerable people from unqualified or unsafe practice is a legitimate and necessary goal. However, the framing of registration must remain centred on practitioner competence and participant safety — not on the elevation of any single profession to a gatekeeping role.
Community disability support in Australia is delivered by a genuinely diverse workforce: social workers, social welfare workers, community development practitioners, disability support workers, occupational therapists, rehabilitation counsellors, and human services professionals. Many of these practitioners bring decades of experience in psychosocial assessment, behavioural support, and complex case management that equals or exceeds the competence of practitioners from more formally regulated disciplines.
I am concerned that the current national debate around social work registration — and the potential alignment of NDIS registration with AHPRA — risks creating a professional hierarchy that does not reflect the realities of the disability workforce. A practitioner with 20 years of experience in behavioural management and psychosocial assessment, working outside a formally registered profession, may be
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1952
considerably more competent than a recently graduated registered practitioner. Registration frameworks must account for this.
The Committee is asked to consider the following principles: • Registration should be competence-based, not profession-based. Demonstrated skills, supervised experience, and continuing professional development should be the criteria — not membership of a single professional body. • Social work, social welfare, community development, community services, disability support, and human services must all be recognised as legitimate pathways to registration, provided competency standards are met. • Alignment with AHPRA is not appropriate for the full breadth of the disability workforce. NDIS practice is not solely a health function, and a health regulation framework is not fit-for-purpose across all practice domains.
- Social and Community Participation Cuts: The Cognitive Infrastructure at Risk The proposed 50 per cent reduction in social and community participation budgets is, from a neurorehabilitation perspective, the most clinically alarming element of this Bill. I write not from abstract concern but from 35 years of direct practice observation — and from a theoretical framework I have developed through that practice, which I will briefly outline.
Distributed Executive Cognition in ABI Following acquired brain injury, executive functions — the cognitive capacities that govern planning, sequencing, initiation, and self-regulation — are frequently impaired. Standard clinical and funding frameworks tend to treat executive function as a capacity residing within the individual. This is clinically insufficient.
In my practice, I have observed and documented what I term distributed executive cognition: the way in which, following ABI, executive functions are enacted not within the individual alone, but through a relational network of supports — practitioners, family members, community workers, and structured programmes. Community participation supports are not peripheral to this network. They are structural components of it.
When one component of this network is removed — whether through funding cuts, workforce turnover, or programme closure — the entire system of distributed cognition can be destabilised. The individual is not simply deprived of a social activity. They lose a functional prosthetic for executive capacity.
A Clinical Illustration Consider a composite example drawn from my clinical experience. A person living with ABI — I will call him Glenn — had, over years of supported community engagement, developed a functional network that compensated for significant frontal lobe deficits. His participation in community programmes provided structure, routine, social cueing, and supported planning. His family provided continuity and memory scaffolding. His practitioners provided coordinated goal-setting and monitoring.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1952
When Glenn’s father developed dementia, one node in that network was suddenly unavailable. The consequences were not proportional to the apparent scale of the change — they were catastrophic. Planning collapsed. Routines failed. Community engagement became inaccessible without support. A single structural disruption unravelled years of carefully built compensatory function.
A 50 per cent reduction in community participation funding does not trim the edges of a plan. For people with ABI and similar conditions affecting executive function, it removes structural supports that are functionally equivalent to mobility aids or communication devices. The downstream costs — in crisis support, hospitalisation, carer breakdown, and loss of independent living — are likely to far exceed any savings achieved.
- The Invisible Cognitive Infrastructure the NDIS Must Not Dismantle The NDIS was designed to fund supports that are reasonable and necessary. For people with ABI and other neurological conditions affecting executive function, community participation supports are both. They are not lifestyle enhancements. They are, in many cases, the mechanism by which a person remains in the community, maintains relationships, and retains the capacity for self-direction.
This invisible cognitive infrastructure is poorly understood in policy settings, because it does not look like a wheelchair ramp or a communication device. It looks like a support worker accompanying someone to a community garden programme, or a day service providing structured activity. When viewed in isolation, such supports can appear discretionary. When understood through the lens of distributed executive cognition, they are load-bearing.
I urge the Committee to recommend that the Bill be amended to exclude acquired brain injury and other conditions affecting executive function from the scope of the community participation budget reductions, pending the development of a clinically informed framework for assessing the functional role of participation supports in cognitive compensation.
Summary of Recommendations • That provider registration frameworks under the NDIS be competence-based and inclusive of social welfare, community development, human services, and disability support disciplines — not restricted to AHPRA-registered health professions. • That the proposed 50 per cent reduction in social and community participation budgets be reviewed with specific regard to participants with acquired brain injury and conditions affecting executive function, for whom these supports constitute functional cognitive infrastructure. • That the Committee recommend development of a clinically informed framework for distinguishing discretionary from functionally necessary participation supports, particularly in the context of neurological disability.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1952
• That the principle of “nothing about us, without us” be meaningfully applied — including to clinical and workforce communities who carry direct knowledge of how these supports function in practice.
I am available to provide information to the Committee if that would assist the inquiry. Respectfully submitted, Darrell Meredith