Submission 1963

Submission to the Senate Standing Committee on Community Affairs

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

Submitted by: , Speech Pathologist (Sole Trader) Date: 28 May 2026

Introduction

I am an experienced speech pathologist based in Victoria specialising in supporting children and adults with disabilities who have complex communication needs, high support needs, and minimal or no speech. My expertise includes the provision of assistive technology supports. Since 2018, I have chosen to operate as a sole trader to maintain autonomy over the quality of care I provide, ensuring that each client and their family receives individualised therapy and capacity-building in their natural environment, comprehensive assessment, and collaborative support with their care teams. Many of my clients and their families have actively sought my services, exercising their right to choice and control, following my previous work in the special education setting (prior to NDIS being rolled out).

Key Concerns with the Amendment Bill

1. Ministerial Power to Cut Funding Without Appeal

• Issue: The Bill grants the Minister the power to reduce funding for any support category by a specified percentage, with no right of appeal for participants.
• Impact: This undermines the fundamental NDIS principle of participant choice and control. My clients, many of whom rely on consistent funding for essential communication devices and therapies, could lose access to life-changing supports without warning or recourse. Such sudden changes can lead to regression in communication skills, increased isolation, and greater reliance on crisis services.
• Recommendation: All funding decisions must be subject to independent review and participant appeal rights. No reductions should occur without transparent justification and adequate notice.

2. Tougher Unscheduled Reassessment Rules and Loss of Review Rights

• Issue: The Bill restricts participants’ ability to request reassessment and removes review rights for automatic plan renewals and funding reductions.
• Impact: Many of my clients have fluctuating or evolving needs. The inability to request timely reassessments or challenge decisions means that supports may not keep pace with their changing circumstances, risking deterioration in health and wellbeing.
• Recommendation: Preserve the right to request unscheduled reassessments and ensure all decisions affecting supports are reviewable by an independent body.

3. “All Appropriate Treatments” Test for Scheme Eligibility

• Issue: The requirement to exhaust all “appropriate treatments” before NDIS eligibility is granted places an unfair burden on participants, especially those with limited financial means.

Submission 1963

• Impact: Many families I work with cannot afford expensive medical reports or specialist assessments. This barrier will disproportionately exclude those most in need, particularly people with complex communication needs who may not be able to advocate for themselves.
• Recommendation: Remove the requirement to exhaust all treatment options prior to eligibility, or at minimum, ensure safeguards are in place to prevent financial hardship and consider the availability and appropriateness of treatments.

Automated Decisions and Algorithms with No Individual Appeal

• Issue: The Bill introduces automated decision-making processes, with no avenue for individual appeal.
• Impact: My clients’ needs are highly individual and cannot be captured by generic algorithms. Automated decisions risk misidentifying support needs, especially for those with complex or fluctuating disabilities, leading to inappropriate or insufficient supports.
• Recommendation: Ensure all automated decisions are subject to review by qualified assessors (e.g., those who have a background in allied health, medicine, disability, child development) and provide clear, accessible appeal pathways for participants.

Additional Concerns

a) Cost-shifting onto Other Government Systems:

I believe these changes will shift costs to other already-stretched systems such as Medicare, hospitals, and the disability pension. Parents of children I work with may be forced to leave the workforce to provide care, increasing reliance on government income support.

b) Provider Sustainability at Risk:

As a sole trader, I invest significant time in comprehensive assessment, collaboration, and capacity building. Unpredictable funding cuts and price caps make it difficult to sustain high-quality, individualised services, and will likely force experienced providers out of the sector.

c) Systemic Waste, Inefficiency, and Psychological Distress for Families – Leading to Cost ‘Blow-out’ of NDIS

The current NDIS processes have been highly inefficient, resulting in significant waste of both participant funding and professional resources. Families are routinely forced to go through lengthy and stressful appeals processes (such as the Administrative Appeals Tribunal, AAT) just to secure basic supports like support worker hours (even if it’s a few hours a week) or continence products. This not only delays access to essential supports but also diverts funds away from direct therapy and meaningful intervention. My time as a therapist is spent writing reports to justify the need for these essential supports. A large amount of the government tax-payer spending on NDIS is then directed to paying lawyers who work for NDIS, to justify reducing participants’ supports in the AATs conducted. I will list more examples of the impact on participants and providers I have observed in my work below, and my recommendations:

• Excessive Administrative Burden: Prior to the NDIS, schemes like the Victorian Electronic Communication Devices Scheme (Yooralla) allowed for straightforward access to communication devices (up to $7,500) with a simple application from a speech pathologist. Now, obtaining even a basic device (e.g., a tablet with a communication app totalling $2,000) requires 5–10 hours of therapy

Submission 1963

• time spent on report writing, appeals, and additional documentation. This is a poor use of both participant funds and professional expertise—money that could be spent on direct therapy is instead wasted on bureaucracy.

• Unqualified Decision-Making: Many of my clients and their families report that the people making decisions about their plans and supports are not qualified to understand complex disability needs. As a result, inappropriate decisions are made, leading to further appeals and wasted resources.

• Coercive and Hostile Communication: Families have described interactions with NDS representatives as coercive and hostile. For example, families are pressured to say their child is “doing well,” which is then used as justification to cut funding. Plan review calls are often made from private numbers at unexpected times, catching parents off-guard and unprepared, and sometimes these calls are not even identified as plan reviews. This practice undermines trust and transparency, and has led to further appeals and distress experienced by the families I work with.

• Psychological Distress: The constant need to fight for basic supports, navigate appeals, and deal with unqualified or unsympathetic staff is causing high levels of psychological distress for families. This stress impacts not only the participant but the entire family unit, reducing their capacity to engage in work, community, and family life.

• Ongoing Cycle of Appeals: The inefficiency and adversarial nature of the system means that families and providers are caught in a cycle of ongoing appeals, further wasting time and resources that could be better spent supporting participants’ actual needs.

Recommendations:

• Streamline access to essential supports, particularly for well-established needs such as communication devices, continence products, sensory supports, and support worker hours, by trusting qualified allied health professionals’ recommendations and minimising unnecessary administrative hurdles.
• Ensure that all decision-makers and phone-based staff have appropriate qualifications and training in disability, allied health, communication needs, child development and trauma-informed practice.
• Implement clear, transparent, and respectful communication protocols for all plan reviews and funding decisions, including advance notice and identification of the purpose of calls.
• Reduce the reliance on appeals and excessive documentation so that participant funds can be used for direct supports, not bureaucracy.

As a sole trader and specialist in complex communication needs, I see first-hand the life-changing impact of the NDIS when it is flexible, participant-driven, and responsive. The proposed changes threaten to erode these foundations, risking harm to some of the most vulnerable Australians. I urge the Committee to reconsider these amendments, and my additional concerns listed above, and uphold the principles of choice, control, and equity for all NDS participants.

Thank you for considering my submission.