NDIA Accountability Project

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Advocates for neurodiversity-affirming disability systems (Provider advocacy)

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

Submission: Submission 208

Submission to the Senate Community Affairs Legislation Committee

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

Submitted by Gladstone Region Autistic & Neurodivergent Network Inc. (GRANN)

To the Senate Community Affairs Legislation Committee, The Gladstone Region Autistic & Neurodivergent Network Inc. (GRANN) thanks the Committee for the opportunity to provide feedback regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

GRANN is a Queensland-based not-for-profit organisation led by and working alongside autistic and otherwise neurodivergent people, families, carers, and community members. We advocate for neurodiversity-affirming, trauma-informed, culturally responsive, and human-rights-based approaches across disability systems, education, healthcare, and community life. Our submission draws upon lived experience, community consultation, disability scholarship, frontline advocacy concerns, and *the realities faced by autistic and neurodivergent people across regional Queensland and broader Australia.We are particularly concerned about the impacts this Bill may have on:

  • Autistic participants* or other wise Neurodiverse individuals*
  • [] People with psychosocial disabilities or intellectual disabilities*
  • [] Multiply disabled individuals*
  • [] Rural communities,* as well as remote areas*
  • [] First Nations peoples*
  • [] Culturally diverse languages*(CALD)communities
  • [] LGBTQIA+ neurodivergent persons*
  • [] Women of gender-diverse identities*
  • [] Individuals experiencing poverty, housing instability*, family violence**,or institutional traumaWhile GRANN acknowledges that ensuring long-term sustainability in NDIS is important,sustainability cannot come at accessibility’s expense,dignitysafetyautonomy****human rights.

We urge Committee to carefully consider structural psychological cultural practical consequences proposed reforms adopt recommendations outlined within this submission.Thank you for considering our contribution.

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

Submission 208 Sincerely, Gladstone Region Autistic & Neurodivergent Network Inc.(GRANN)

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

Submission 208

Human Rights and Neurodiversity Framework

GRANN submits that all NDIS reforms must be interpreted consistently with Australia’s obligations under the United Nations Convention on the Rights of Persons with Disabilities (CRPD), including rights to autonomy, community participation, supported decision-making, freedom from discrimination, cultural safety, and equal recognition before the law. Neurodivergence is not inherently pathological. Autism, ADHD, Tourette’s, dyslexia, intellectual disability, psychosocial disability, and other neurodevelopmental differences are part of natural human diversity. Many barriers experienced by neurodivergent people arise not from neurology itself but from inaccessible systems, stigma, poverty, sensory-hostile environments, institutional exclusion, diagnostic inequity, and inadequate support structures.The NDIS must therefore operate from a neuro-affirming, trauma-informed, culturally responsive, and human-rights-based framework rather than deficit-based assumptions centred on productivity, behavioural conformity or normative functioning.GRANN is concerned that aspects of the proposed Bill risk shifting the NDIS further toward surveillance compliance gatekeeping cost containment at the expense participant wellbeing inclusion.

Concerns Regarding Functional Capacity Assessments

GRANN holds significant concerns regarding proposals for standardised functional assessments centralised eligibility testing.Autism ADHD psycoshical disabilty intellectul disabilit and other neurodevolopmental differnces present heterogeneously across contexts environment communication modes traum histories sensoy conditions suppor access co occuring disabilities Function capacity static linear reliably measurable through single deficit based assessment tool.Many autistic ndeivrgnet peple experience fluctuating function depending Autistic burnout Sensory overload Trauma exposure Masking demands Mental health Chronic illness Environmental accessibility Social expectations

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

Submission 208

communication stressors A participant may appear articulate or “capable” during a brief assessment while simultaneously being unable to sustain employment, education, self-care, social participation, executive functioning, emotional regulation, or independent living over time.

GRANN is deeply concerned that standardised assessment systems may reproduce harms seen internationally where disabled people are disbelieved, retraumatised, excluded, or forced to perform distress in order to access support.* Particular risks exist for:

  • women and gender-diverse Autistic people who mask heavily
  • First Nations participants whose communication styles differ from dominant assessment norms
  • CALD participants facing language barriers
  • individuals with trauma histories
  • intellectually gifted autistic people whose adaptive functioning difficulties are overlooked
  • adults diagnosed later in life
  • rural participants without access to specialist clinicians
  • people with co-occurring psychosocial disabilities
  • participants unable to afford repeated specialist reports

*GRANN strongly opposes any assessment model that reduces disability access to algorithmic scoring systems, short-term observation, productivity measures, or narrow behavioural interpretations. We recommend: - multidisciplinary and contextual assessment processes

  • strong appeal mechanisms
  • participant input into assessments
  • culturally safe assessment pathways
  • recognition of fluctuating and invisible disability
  • reduced reassessment requirements for permanent disabilities
  • safeguards against automated decision-making

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

Submission 208

Diagnostic Gatekeeping and Socioeconomic Inequity

Access to diagnosis in Australia is profoundly unequal. Comprehensive autism and ADHD assessments frequently cost thousands of dollars and involve waitlists exceeding 12 to 36 months, particularly in regional and rural Queensland. Communities disproportionately affected include:

  • low-income families
  • First Nations communities
  • CALD communities
  • women and gender-diverse people
  • adults missed during childhood
  • people experiencing homelessness
  • survivors of domestic and family violence
  • people leaving institutional care
  • rural and remote families Any reform that relies more heavily upon formal diagnosis, repeated reassessment, specialist evidence, or extensive documentation risks structurally excluding people already experiencing disadvantage. GRANN is particularly concerned about the cumulative financial and emotional burden of repeatedly requiring participants to “prove” disability permanence. Disability support systems should not privilege those with greater financial resources, educational literacy, geographic proximity to specialists, or ability to navigate bureaucratic systems.

Funding Adequacy and Restrictive Cost Controls

GRANN is deeply concerned by proposed mechanisms enabling tighter funding caps, restricted support categories, and increased limitations on participant flexibility. Supports often labelled “non-essential” are frequently the very supports preventing:

  • crisis presentations
  • school refusal

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

Submission 208

  • family breakdown
  • homelessness
  • institutionalisation
  • hospitalisation
  • mental health deterioration
  • social isolation
  • suicidality

Social participation supports, sensory regulation supports, communication supports, peer supports, support coordination, therapies, and capacity-building services are not luxuries. They are foundational to autonomy, participation, dignity, safety, and long-term wellbeing. Rigid funding caps fail to recognise that neurodivergent support needs fluctuate significantly cross the lifespan and in response to stress, burnout, trauma, environmental change, and access barriers.

GRANN recommends: no blanket therapy caps -participant-centred flexibility -preservation of capacity-building supports -legislative oversight of funding restrictions -protections preventing plan reductions during transition periods -preservation of participant choice and control

Foundational Supports and Service Gaps

GRANN is deeply concerned that proposed “Foundational Supports” remain poorly defined, inconsistently funded, and unavailable across many regional communities. Participants risk being deemed ineligible for NDIS supports on the assumption that mainstream or foundational systems will provide assistance that does not exist in practice. Across regional Queensland, families already face: -severe allied health shortages -absent autism-specific supports

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

Submission 208

  • long waitlists
  • inadequate school inclusion
  • inaccessible mental health systems
  • transport barriers
  • housing shortages
  • limited crisis services

Shifting responsibilities away from the NDIS without first guaranteeing accessible, enforceable, and adequately funded alternative systems risks abandoning vulnerable participants. GRANN strongly opposes reforms that create “service cliffs” where people are assessed as too disabled for mainstream systems but not disabled enough for the NDIS.

Automation, Surveillance, and Privacy Concerns

GRANN holds significant concerns regarding increased automation, algorithmic decision- making, data-sharing powers, and digital surveillance mechanisms within the proposed reforms. Automation within disability systems carries substantial risk when applied to populations whose communication, behaviour, support needs, and presentation may not align with neurotypical assumptions. Algorithmic systems trained on incomplete or biased datasets may disproportionately disadvantage autistic and neurodivergent participants through: * inaccurate risk flagging * inappropriate fraud suspicion * automated funding reductions * inaccessible communication systems * decontextualised behavioural interpretation * failure to recognise fluctuating support needs Many Neurodivergent participants already experience significant distress interacting with bureaucratic systems, unclear administrative processes, phone-based communication requirements, and compliance-heavy reporting structures.

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

Submission 208

Increased automation risks intensifying anxiety, shutdowns, disengagement, and barriers to self-advocacy.

GRANN Recommendations on Automated Processes Safeguards:

  • Meaningful human oversight of automated processes;
  • Transparent disclosure regarding algorithmic use;
  • Participant rights in requesting a review conducted manually or with another person present,
  • External auditing mechanisms established specifically designed to detect bias within algorithms used during eligibility determination process ;
  • Accessible explanations provided when decisions are made using artificial intelligence tools;
  • Prohibition against fully automating decision-making related directly towards determining an individual’s qualification under this scheme without any form of manual intervention whatsoever;
  • Informed consent obtained prior sharing personal data amongst third parties involved either indirectly through collaboration agreements signed between organizations operating independently yet still connected via shared resources such as databases etc.,
  • Rights granted allowing individuals affected by incorrect information contained therein may request correction thereof.

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

Submission 208

First Nations autistic and neurodivergent people experience intersecting harms arising from colonisation, systemic racism, geographic isolation, child removal histories, institutional distrust, diagnostic inequity, and culturally unsafe service systems. Western deficit-based disability frameworks may fail to recognise culturally distinct communication styles, kinship systems, sensory practices, and community-based understandings of disability and support. Fear of institutional intervention, child protection involvement, or stigma may discourage some families from seeking diagnosis or support. GRANN recommends:

  • increased funding for Aboriginal Community Controlled Organisations
  • culturally governed disability services
  • culturally safe assessment pathways
  • employment of First Nations neurodivergent peer workers
  • community-led outreach and navigation supports
  • flexible evidence requirements for remote communities

CALD and LGBTQIA+ Neurodivergent Communities

CALD Neurodivergent communities often experience additional barriers including:• language access limitations• stigma surrounding disability• migration-related trauma• limited understanding of the NDIS• inaccessible information systems• interpreter shortagesLGBTQIA+ neurodivergent people experience elevated rates of mental distress,discrimination, homelessness, bullying, family rejection, and service exclusion.Many services remain inadequately trained in supporting people with intersectingeurodiverse identities. The NDIS workforce must therefore embed:- Neurodiversity-affirming practice

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

Submission 208

  • LGBTQIA\u{1d7e}a \u{f5b9}\n- Cultural Safety\n- Trauma-Informed Care\n- Communication Accessibility\n- Supported Decision-Making Principles

Workforce and Professional Practice Concerns The effectiveness of the NDIS relies heavily upon the quality, knowledge, ethics, and accessibility of its workforce.

GRANN is concerned by the ongoing prevalence of deficit-based and behaviourist approaches within parts of the disability sector, including practices prioritising compliance masking behavioral normalisation or suppression of autistic communication styles Many neurodivergent participants report harm arising from:

  • Coercive Behavioural Practices * Sensory invalidation Infantilization Unsupported communication needs Pathologizing language Restrictive practices Inadequate understanding of autistic burnout and trauma GRANN recommends mandatory NDIA provider training in: Neurodiversity-affirming practice Trauma-informed care supported decision-making Communication accessibility cultural safety LGBTQI+ inclusion alternatives to compliance based behavioural models

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

Submission 208

Additional investment is urgently required in:

  • regional workforce development
  • peer-led services
  • telehealth accessibility
  • rural practitioner incentives
  • independent advocacy services

Appeals, Advocacy, and Procedural Fairness

Participants must retain accessible, timely, transparent, and fair pathways to challenge NDIA decisions.

GRANN strongly opposes any reforms that reduce participant rights to review, appeal, advocacy, or procedural fairness. Many neurodivergent participants already struggle navigating legalistic and bureaucratic systems, particularly without advocacy support. Independent advocacy services are critically underfunded despite increasing demand.

GRANN recommends:

  • guaranteed access to independent advocacy
  • accessible review processes
  • plain-language communication
  • trauma-informed appeals systems
  • funded support persons during reviews and reassessments

GRANN Recommendations

GRANN recommends that the Senate Committee:1 Retain streamlined or guaranteed access pathways for Autism and permanentneurodevelopmental disabilities.2 Prohibit fully automated eligibility and funding decisions.3 Require human rights impact assessments for major NDIS reforms.4 Embed neurodiversity-affirming and trauma-informed principles within legislationand policy.5 Reduce unnecessary reassessment requirements for permanent disabilities.

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

Submission 208

  • Guarantee participant access to independent advocacy.
  • Protect participant data privacy and require informed consent for data-sharing.
  • Prevent funding reductions during transition arrangements.
  • Ensure foundational supports are genuinely funded and accessible before limiting NDIS access. Mandate neurodiversity training for NDIA staff, planners, assessors, and providers.
  • Ensure assessments are multidisciplinary, contextual, culturally safe, and appealable. -Increase investment in regional, rural, and peer-led neurodivergent services. Expand culturally safe supports for First Nations and CALD communities. Ensure all reforms uphold participant autonomy, dignity, and supported decision-making rights.

GRANN acknowledges: The importance of ensuring sustainability is acknowledged; however: sustainability cannot be achieved through exclusion, surveillance gatekeeping service withdrawal or shifting burden onto families already overstretched mainstream systems. Autistic otherwise Neurodivergent people deserve systems grounded dignify autonomie accessibility cultural safety genuine inclusion. Proposed reforms risk deepening inequities unless significant safeguards amendments community led redesign occur.

The Senate Committee should carefully consider lived realities of neurodiverse Australians amend the bill ensure future NDIS remains rights-based accessible truly supportive generations. In solidarity with community Gladstone Region Autistic & Neurodivergent Network Inc. (GRANN)