Submission Regarding the National Disability Insurance Scheme Amendment

Securing the NDIS for Future Generations) Bill 2026 - Submission 2098

Letter Content

To Whom It May Concern, I write as a speech pathologist working closely with children with disability, as well as their families and carers across various settings. Strongly objected several amendments within the National Disability Insurance Scheme Amendment Securing the NDIS For Future Generations) Bill 2026 While I acknowledge importance protecting long-term sustainability NDIS many these proposed changes risk undermining original intent scheme will have serious negative consequences participants family care front line allied health providers In particular These Amendments place disproportionate emphasis cost containment over Participant wellbeing functional outcomes equitable Access supports

Objection To Proposed Definition Functional Capacity Schedule Section 9B

The proposed definition under section is deeply concerning because it requires assessment person’s Ability undertake activities without assistance from other people assistive technology or modifications in context excluding environmental personal circumstances This approach fundamentally misunderstands disability contradicts contemporary evidence-based practice social model of disability Function capacity cannot be accurately measured isolation Supports technologies communication systems environments relationships enable participation As Speech Pathologist regularly work individuals whose Communication abilities significantly enhanced through AAC devices visual support Environmental Modifications communication partners therapy intervention artificially exclude these supports consideration creates inaccurate harmful representation Person actual functioning Participation needs This amendment risks:

• reducing access for Participants complex communication Needs; disproportionately disadvantaging autistic Individuals People intellectual disability; ignoring real-world contexts which disability experienced creating inconsistent subjective access decisions Objection to restrictions on unscheduled plan reassessments (Schedule Part) The proposed Changes sections and A significantly limit participant ability request re-assessment unless meet strict thresholds relating significant ongoing changes

National Disability Insurance Scheme Amendment

Submission:2098 This fails to recognize the dynamic nature of disability and support needs. Participants often experience changes in communication, behavioural mental health education participation family circumstances or caregiver capacity require timely adjustment before a crisis occurs. extending decision timelines from days will create substantial delays access essential supports For many families speech pathology supports are preventative building Delays reassessment lead deterioration behaviour increased hospitalisation school refusal carer burnout breakdown placements informal greater long-term costs scheme.

National Disability Insurance Scheme Amendment Bill 2026

Submission 2098

• inability for participants to continue clinically necessary supports. Speech pathalogy services often rely on continuity, long-term intervention, and therapeutic trust. Sudden reductions in funding can reverse years of progress.

5. Objection to automatic plan renewals without review (Schedule 1, Part 5*, section* 50A The proposal for plans to automatically renew without meaningful reassessment or review is highly problematic. Participants’ needs change over time. Children develop, school demands evolve, communication systems require updating, and carers age or experience burnout.The proposed framework: • removes opportunities for collaborative planning; • reduces participant voice and choice; • risks outdated supports being rolled over; • may lock participants into inadequate funding arrangements.Importantly,subsection 50A(4) states that automatic renewals do not involve a reviewable decision.* This significantly weakens procedural fairness and participant rights.
6. Objection to changes prioritising “scheme sustainability” over participant needs (Schedule* one, Part six) The amendments repeatedly elevate“financial sustainability asa guiding principle indeterminingsupports.While*sustainabilityisimportant,*theseamendmentsrisk shifting the Scheme away from its core purposeof enabling participation,inclusion,and quality off lifefor people with disability.Of particular concern are:maximum funding capsand intensity limits forsupports;increased emphasis on lower-cost supportsover clinically appropriate supports;prioritisation of peer-reviewed evidenceover participantspecific outcomes andclinician expertise.Speech pathology interventionishighly individualised.Many effective supports forecommunication anda ndparticipationmaynotyet have extensive largescale published evidencedespite strong clinical effectiveness fora nindividualparticipantTheproposed hierarchyo fevidence riske xcluding innovative,personalised, an dneurodiversity-affirmingsupports
7. Objectionto increased relianceon familiesa ndcarers (Schedul e 1, Part six*, subsection* 34(1G)–(IK))*

Submission 2098

The proposed provisions place excessive responsibility on parents, carers, and informal supports, particularly those provided by mothers or women in general. As a clinician, I regularly witness carer exhaustion, emotional distress, financial hardship, and relationship breakdown resulting from inadequate formal supports.The proposal that parents are presumed responsible for “substantial care and support” and hat supports should not reduce “burdens on parental time” is deeply concerning.Families arealready carrying extraordinary responsibilities.These amendments riske: • increasing unpaid care burdens; • worseningcarermental health; • reducing workforce participation ofparents anda carers,perticularlywomen; •increasing familybreakdownandsafeguarding concerns. Objectionto tighter permanence requirements andremandatory treatment expectations (Schedule1 , Part7) Theamendments requiringparticipants to undertake “all appropriate treat ment” before impairments arereconsidered permanentar problematicpotentially discriminatory.Theseprovisions: • failaccountfor treataccessibility ; • disregard geographicfinancial barriers; • risk coercing participants into unwantedor unsuitable interventions; • create uncertaintyforsubjects with fluctuatingorevolving disabilities. The bill also states thattreatment may still be considered“appropriate treatment regardlessof whethera person can realistically access it.Thisis inequitable disconnectedfrom the realities faced by regional rural First Nations and disadvantaged Australians Objectionexclusion basedonaccessalternative supports(Schedule 8,Part9)The proposed alternative supportrequirementscreate substantialrisk thatparticpants willbe excluded fromthe NDIS assumption another system provide support.In practice many mainstream systems are already overstretched unable meet disability related needs adequately This amendment risks creating: service gaps cost shifting between systems delays in intervention poorer outcomes for partici pants.

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

Submission 2098

Children and adults with communication disabilities are particularly vulnerable to falling goingthroughgapsbetweenhealtheducationmentalhealthishdisabilitysystems. In conclusionthe proposedamendmentscollectivelyrepresentasignificantshiftawayfromthefoundationalguidingprinciplesofthenNDIS.Theyprioritiseadministrativeefficiencyandcostcontainmentoverparticipantrightsinclusionearlyinterventionandperson-centredsupports.As aspeechpathologistIseedaysthetransformativimpactthattimelyindividualisedandadequatelyfundedsupportshaveoncommunicationsafetyindependenceparticipationquality of life.I urge the Government toreconsiderthese amendmentsundertake genuine consultationwithpeoplewithdisabledfamiliescarersandfrontlineallied healthprofessionalsbeforeproceeding.The NDISMustremaina schemeempowers people disabletparticipate fullyinsocietynotone that narrows access, shifts burdens onto families,and limits supports throughincreasinglyrestrictivecriteria.Yours sincerely, speech pathologist