Submission 1994
COMMITTEE
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
NDIS provider & parent of NDIS participant
South Australia
26 May 2026
I am writing to express serious concerns about the proposed NDIS Amendment Bill and its impact on disability service delivery, workforce sustainability, access to evidence-based supports, and the protection of people with high and complex support needs.
CONTEXT: PROFESSIONAL ROLE AND EXPERTISE
I operate a 20 year-established disability support delivering specialised therapeutic services to clients with developmental and neurological conditions, including autism, ADHD, and associated support needs. I run a private practice and work with some of the most complex and vulnerable clients in the disability sector—particularly non-speaking autistic children and adults, people with profound intellectual disability, and those with severe behaviours of concern requiring intensive therapeutic intervention and are often unresponsive to more mainstream therapies available.
I am speaking from both professional expertise and lived experience.
SPECIFIC CONCERNS
1. THE “GENERALISABLE EVIDENCE” PROBLEM: EXCLUDING HIGH-NEED POPULATIONS FROM THERAPY ACCESS
The Bill introduces a critical gatekeeping mechanism that will deny evidence-based therapies to people who need them most. The legislation states that the CEO must give the greatest weight to evidence that is “published, peer reviewed and generalisable.” Further, the CEO may refuse funding if there is “limited or no research or evidence of the kind mentioned” — even when evidence specific to the participant exists.
This is catastrophic for non-verbal autistic children, people with profound intellectual disability, and those with severe support needs. These populations are systematically absent from generalised research. The very individuals for whom specialised, intensive therapies are most critical are the ones most likely to be excluded by this evidence standard.
I have already experienced this. Clients with non-speaking autism, severe intellectual disability, and complex behaviours requiring intensive intervention have been denied access to evidence-based music therapy because the NDIA has decided the research base is “insufficient” — not because the therapies are ineffective, but because adequately representative research does not exist.
The Bill relies on generic meta-analyses (such as Sandbank et al., 2024, JAMA Pediatrics) that do not represent minimally verbal autistic children or those with severe intellectual disability. The authors themselves caution practitioners to be especially careful when determining intensity for high-support- eeds populations at risk of injury if unsupported. This Bill ignores that caution and provides no protection for people who will be harmed by insufficient therapy.
2. THE 50% CUT TO SOCIAL, CIVIC AND COMMUNITY PARTICIPATION SUPPORTS
This proposed cut will directly harm the viability of person-centred, evidence-based disability services. My daughter has complex behaviours of concern and is unable to safely access the community. This is
Submission 1994
no meaningful life to be home bound which also increases pressure and stress on our family. Her being able to leave the house to be part of society is a goal and one she may never achieve without support.
For my non-verbal clients and those with profound support needs, group-based community activities are often impossible. A 50% budget cut forces a false choice: close services or reduce quality. I have spent 20 years building trust-based relationships with clients and families who have often been failed or rejected by mainstream services. I cannot absorb a 50% revenue reduction while maintaining the supervision, training, and quality that makes my services safe and effective. Clients who need support to attend therapy are at risk of not being able to attend.
3. MAXIMUM THERAPY INTENSITY CAPS: RISK OF HARM FROM INSUFFICIENT INTERVENTION
The Explanatory Memorandum states the Bill may “specify a maximum intensity for a particular therapy support if research shows that any more than that intensity does not add any benefit for an individual.” The example given is “12 hours per year of a particular kind of therapy support.”
For a non-speaking autistic child or a person with severe intellectual disability requiring intensive speech, motor, and nervous system support, 12 hours per year is not intervention—it is abandonment. This approach provides no protection for participants at risk of harm due to insufficient intensity.
Our clients with severe behaviours of concern, self-injurious behaviours, or profound speech and motor delays require sustained, intensive therapeutic intervention. Arbitrary caps based on generic research will not reflect their actual needs. The Bill provides no mechanism to protect people who require more intensive support to prevent harm.
4. WORKFORCE VIABILITY AND JOB LOSSES
The combined impact of 50% support cuts and maximum intensity caps will force the closure of specialist services.
A 50% cut to social and community supports, combined with evidence-based caps that exclude high-need populations, means we cannot maintain our workforce. Support workers will lose jobs. The expertise and training they represent will be lost. The disability sector is already struggling with workforce recruitment and retention; this bill makes it worse.
5. ACCESS AND ELIGIBILITY: EXCLUDING PEOPLE WHO MOST NEED SUPPORT
I have lived experience of the gatekeeping that this bill will formalise and worsen.
More critically, it will exclude precisely the people I serve: non-speaking autistic individuals, people with severe intellectual disability, and those with complex behavioural needs. The bill claims to clarify eligibility. In practice, it narrows access for people with genuine, significant support needs.
6. SYSTEMIC RISK: CASCADE EFFECTS
When specialist disability services close, the burden shifts to emergency services, mental health systems, and hospitals. When people lose access to the therapeutic supports they depend on, their capacity decreases. Crisis presentations increase.
For my non-verbal clients and those with severe behaviours, loss of intensive therapeutic support will lead to increased self-injury, aggression, and hospitalisation. The costs will shift to emergency departments, not disappear. This is not sustainability. It is cost-shifting.
7. LOSS OF CHOICE AND CONTROL: RISK OF RETURN TO INSTITUTIONAL MODELS
Submission 1994
The NDIS was established in response to decades of systemic failure within institutional and welfare-based disability systems.
Australia has a documented history of abuse, neglect, segregation, restraint, overmedication, and loss of autonomy within government-run and congregate disability settings.
The Disability Royal Commission heard extensive evidence of these harms. This Bill risks undermining one of the foundational principles of the NDIS: that disabled people should have choice and control over the supports they receive and the lives they lead.
When funding is reduced, when therapeutic supports are capped below safe levels, and when specialised community-based services become financially unviable, people with high and complex support needs lose real choices. Families are not choosing between equal alternatives — they are being cornered into crisis.
For non-speaking autistic individuals, people with profound intellectual disability, and those with severe support needs, the collapse of person-centred supports can lead to increased hospitalisation, mental health admissions, restrictive practices, family breakdown, homelessness, or placement in institutional and congregate settings.
This is particularly concerning because the people most affected are often those least able to advocate for themselves.
The NDIS was intended to move Australia away from systems where disabled people were controlled, segregated, and deprived of autonomy. Policies that remove access to individualised supports and force people into crisis pathways risk recreating those conditions in another form.
Choice and control cannot exist in principle only. It must exist in practice. If participants are denied access to the supports that allow them to safely remain in their homes, communities, relationships, education, and workplaces, then the practical outcome is coercion through lack of alternatives.
Any reform to the NDIS must be assessed not only through a financial lens, but through a human rights lens, including Australia’s obligations under the Convention on the Rights of Persons with Disabilities.
8. LACK OF CONSULTATION AND EVIDENCE
The disability sector—particularly therapists and services supporting high-need populations—was not meaningfully consulted. Advocates and service providers are expressing serious concerns that remain unaddressed.
Where is the evidence that “generalisable evidence” standards improve outcomes for non-speaking autistic children or people with severe intellectual disability? Where is the modelling of workforce impact? Where is the cost accounting showing that shifting costs to emergency services actually saves money?
This bill is being rushed through Parliament without adequate scrutiny.
WHAT NEEDS TO HAPPEN
I am asking the Senate Committee to:
- Remove or substantially revise the “generalisable evidence” standard to protect access for underrepresented populations (non-speaking autistic people, those with severe intellectual disability, high-support-needs individuals). Require that individualised evidence and participant-specific outcomes are given equal weight.
Submission 1994