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

Submission to the Senate Community Affairs Legislation Committee

National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026 Amanda Larkin Founder, Cultivating Curiosity AU Pty Ltd Unregistered NDIS Provider delivering support under Capacity Building – Improved Daily Living Skills

About Me

I run Cultivating Curiosity AU Pty Ltd, a business owner in Perth, Western Australia. I am an unregistered NDIS provider delivering Capacity Building - Improved Daily Living Skills supports to a small participant cohort. These participants make up less than 20% of my client base. My qualifications cover both disability support and education. They include: Bachelor’s Degree in Primary Education; Certificate IV in Disability; Diploma of Counselling; Mini-Certificate of Gifted Education; certified LEGO® SERIOUS PLAY® facilitator training as Coach at Growth Coaching International); additional training on executive function supports tailored towards twice-exceptional individuals; The combination is deliberate because these participants require comprehensive assistance with their disabilities which are not isolated but rather interact through co-existing conditions such as school environments or developmental stages alongwith gaps between what they can think versus manage within any given day. The provided services encompass areas like Executive Functioning Emotional Regulation Metacognitive Development Transition Planning all grounded upon diagnosed disabilities documented via service agreements & reports. As someone who has lived experience being Twice Exceptionally Diagnosed according DSM5 criteria while raising two similarly exceptional children myself, in the year 2016 our program Camp Curiosity was nominated for WA Disability Support Award under Excellence In Innovation category specifically designed around meeting needs unique to this demographic group falling somewhere between giftedness spectrum disorder and traditional special educational requirements systems thereby highlighting significant gap left unaddressed by current NDIS framework. This nomination directly conflicts against provisions outlined hereinunder proposed legislation aimed at regulating accessibilities offered exclusively reserved only for registered providers thus potentially excluding us from providing necessary support required by said population due compliance costs pushing out specialist providers altogether The Committee should ask what exactly gets lost when regulatory measures force exclusion of highly specialized yet innovative non-profit organizations serving niche populations.

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

Submission 2057

I am submitting under my name because an anonymous submission carries less weight. That is not a comfortable decision. As a small unregistered provider I know attaching my name public submission critical of creates real risk scrutiny practice Participants face same calculation Challenging decisions about your plan funding treatment carries real power life Does make these concerns accurate Committee should understand chilling effect people most affected by this Bill theoretical It reason providers participants share these concerns will submit Accountability gap matters too.

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

Submission 2057

families, these are systems that have already failed to provide adequate support. “More appropriately funded elsewhere” may describe where government prefers the cost to sit. It does not mean equivalent support actually exists. Recommendation 1. Retain “arising from” in paragraph 34(1)(aa)",or provide explicit guidancethat cumulativeand interacting impairments meetthe causal standard.Exclusions based on other service system responsibility should applyonly wherethosesystems demonstrably providesequivalent accessandsupport.`

Reasonable and Necessary`

schedule,Part appliesthesamelogicto thereasonableand necessary framework.SUPPORTS must now be consistentwith financial sustainabilitymeet elevated evidencestandards,and bemasured against undefined“comparablesupports”.Financialsustainabilitybelongs at theschemelvel.Itshouldnotdeterminewhether an individualparticipant’ssupport needsare considered legitimate.When itoperatesattheplanninglevel,genuine need risks being reclassified as unaffordable.Thisframework privileges large-scalegeneralisable evidence.That disadvantages neuro affirmingrelationalandindividualised supportsparticularlyfor participant groups too smalltogenereconventionalevidencebases.Fortheparticipants those programs serve they often only work.Decidingthey do no qualifyas evidenced-based because they lack largescaletrialevidenced is neutralItis a decision about whose ecount. comparablesupports” ist defined.A cheaper supporst not automatically comparable. A group programist not comparableno to individualeaching for aparticipantwhose masking makesgroup settings harmfulA generalist is nocomparabletospecialist when specialist knowledge whatmakes the support effectiveRecommendation 2. Removefinancial sustainabilitycriterionatatthe individual planning level.Define “comparablesupporsaccordingfunctional equivalence, cost Requireevidences tandstandardsaccommodate relationalneuro affirminsmall-cohort approaches.

AssessmentTreatment and Access`

schedule`,Part assesses functional capacity without supports assistive technology or environmental context.Many participants Iwork with functionbecause of scaffoldingco-regulation,and relatingsafetyRemovingthosesupports doesnot revealtruecapacity.It measures functioningwithout conditions required participation.The Bill riskinterpreting successfulsupportasa evidencethat less supportrequired.

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

Submission 2057

Reassessment

Schedule 1, Part 2 limits reassessments to significant, ongoing, and unanticipated changes. For autistic burnout and psychosocial deterioration, distress is often invisible until it becomes acute.Early intervention can be more effective but also less costly.This bill makes preventative responses harder.

Appropriate Treatment

Schedule 1, Part 8 introduces “all appropriate treatment” in permanent assessments.The bill does define: a) What “appropriate” means; b) Who determines this; or c) How harm assessment works.Harm from therapeutic interventions can occur when treatments do not consider participants’ co-occurring conditions fully.Participants who decline or modify such therapies should retain their NDIS supports without penalty. The framework fails adequately recognizing participant autonomy or informed refusal of treatment where these conflict with values culture prior experiences of harm.Tension exists between this principle and the NDIS’s choice control principles.

Recommendation: Define“Appropriate treatment”to require considerationof aparticipant’s full profileco-occurrenceconditionsnot onlytheir primary diagnosis.Provide explicit protectionsforparticipantsfamilieswho declinetreatment onthe basisdocumentedharmor contraindication.Require permanence determinationsaccount actual geographic cultural systemic access barriers.Affirm participanta utonomyinformed decision-makingwithoutpenalty.

Provider Viability

Schedule2 expands provider definition as foundation for broader mandatory registration.Same logic that narrows legitimate support needs now narrows what countsaslegitimate providers.Compliance infrastructureandorganisational scale are rewarded.Specialisationandrelns continuityare not.

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

Submission 2057

For small specialist providers operating under Capacity Building – Improved Daily Living Skills,

registration costs already exceed revenue derived from NDIS-funded work. This is not unusual. It is the reality forsmallspecialistprovidersoperatingunderCapacityBuilding–ImprovedDailyLivingSkills, registrationcostsalreadyexceedrevenuederivedfromNDIS-fundedswork.Thisisanormalityformany experiencedprovidersonworkingwithcomplexneurodivergentparticipants.providerswhohavebuilt specialknowledgeoveryearsholdrelationshipswithparticipantsthatcannotsimplybetransferred elsewhereandwhoofferflexibilitythatlargerorganisationsoften cannot. Ifmandatoryregistrationisextendedtoprovidersinthiscategorythemoostlikely outcomeisinnotimprovedquality.Itispethatprovidersthosevaluecomesfrosspecialisationcontinuity leavethe market.Whatreplacesthemwilltypicallybe organisationswithestheinfrastructuretoabsorbcompliancecostsandstandardised servicemodesthatareleastwellforthecomplex participants. Iamalreadyaccountablethroughformalserviceagreementslinkedtotargetgoals andregularreportingagainstreasonableandsufficientcriteria.Theideathatall unregistered providerrepresentan accountabilitygapdoes notreflect theway manysmallspecialists provideactuallyoperate Recommendation 4.Legislate agenuine tiered enrolment model separating low-risk specialist capacity-building supports from high-risks personal care supported living services.Light-touchenrolm entpathways forsolepractitionersandsmall specialists providers should be included in primary legislation rather than left to subordinate instruments.Anyimpactanalysisofexpandedregistrationshouldmodel sole-trader small-providerexitrates, andre sultant impact on participant access to spesialistsupports. 7.Closing ThisBillcontainsonecoreissuethreaded throughoutitsprovisions.Itassumes that complexinteractingcontextualdisabilitycanb assessed,funded,treatedandsupported throughframeworksthatprioritise directisolatedsingle-cause relationships TheparticipantsIworkwithhave realpermanentsignificant disability.Thereis oftennoequivalentsupportsystemavailable tot themoutsidetheNDIS.Thesuppor ts workforthemarefrequentlytheverysupporthiss Billmakeshardesttoaccess sustain. I amaskingTheCommitteetoaddressthis issueat itsrootando make recommendationsprotecttheschemeforthepople itwasbuilttosupport.