National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission: Submission - National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 To: Senate Community Affairs Legislation Committee Subject: Subject - Submission : NDIS Future Generations Bill 2026
About Nacre Consulting
Nacre Consulting is an Australian business coaching and advisory company specialising in allied health business strategy, leadership, operations and sustainability. We work closely with allied health business owners across Australia, including providers delivering services within and alongside the NDIS. Our work gives us direct insight into the operational, financial, workforce and governance pressures affecting small and medium allied health businesses. This submission is informed by our ongoing work with allied health business owners navigating NDIS reform, pricing pressure, workforce shortages, compliance obligations and uncertainty about future service models.
Concerns We Have
Our concerns relate to parts of the Bill that may reduce or restrict participant supports, increase reliance on broad funding rules, extend administrative decision-making powers, reshape access to capacity-building and participation supports. The changes could have significant practical consequences for participants, families, Allied Health Providers & Workforces delivering NDIS Services. Our focus includes individualised support, early intervention, provider viability, workforce stability, assessment quality service infrastructure needed keep Scheme effective.
Position
Nacre Consulting conditionally supportive reforms improving Sustainability Integrity Long-term Viability NDLS. NDIS must be protected current Future Participants need address Fraud Poor-quality Service Delivery Inconsistent Planning Unustainable Cost Growth. However several elements risk creating serious unintended Consequences if implemented without stronger safeguards. Reforms intended improve sustainability but also carry risks Functional Outcomes Early Intervention Participant Independence Family Capacity Workforce Stability Provider Viability. Concern not Reform itself. The concern is Reform reducing Access To Capacity Building Supports before alternative systems are ready relying too heavily Broad Funding Rules weakening Provider Workforce delivering Safe Effective outcomes-focused Support.
What The Reforms Get Right
The NDIS needs Stronger integrity settings.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 2146
Participants, families, taxpayers and ethical providers all benefit when fraud, poor practice and weak accountability are addressed. The Scheme also needs clearer boundaries around what it funds, how decisions are made, and how public investment translates into meaningful outcomes.
Many allied health providers support better evidence, clearer planning, stronger quality safeguards and more transparent expectations.
But sustainability must not be achieved by shifting cost and risk onto participants, families, clinicians and small providers.
Concern 1: Administrative Efficiency Must Also Be Examined
It is reasonable for taxpayers to expect the NDIS to be financially sustainable. It is also reasonable to expect the Agency and broader administrative system to operate efficiently, transparently and responsibly. Savings should not be sought primarily through reduced participant supports or destabilising the provider workforce before administrative efficiency has been fully examined. A sustainable Scheme requires a fit-for-purpose administration: one that reduces duplication, improves decision-making consistency, uses public funds responsibly, communicates clearly, and avoids costly delays, rework, disputes and appeals. There are likely significant savings to be found in better Scheme administration, clearer processes, improved planning quality, stronger fraud detection, reduced bureaucratic churn and more efficient internal systems. Before reducing capacity-building and participation supports, Government should demonstrate that administrative inefficiency has been identified, measured and addressed.
Concern 2: Broad Funding Reductions Risk Undermining Individualised Support
The Bill appears to create mechanisms that may allow funding reductions across categories of supports, rather than through fully individualised assessment of need. This is a serious shift. Capacity-building and participation supports are not optional extras for many participants. They are often the supports that help people develop skills, maintain routines, participate in education, engage in work, reduce reliance on family carers and build greater independence over time. A system-wide reduction may appear administratively efficient, but it risks treating very different participant needs as if they are the same. For children, people with psychosocial disability, people with fluctuating conditions and people with complex functional needs, reduced access to capacity-building support may increase long-term reliance on crisis services, family carers, health systems and more intensive funded supports later. Short-term budget control may therefore create longer-term cost and harm.
Concern 3: Foundational Supports And Thriving Kids Are Not Yet Ready
The proposed reforms are occurring alongside major changes to early childhood and foundational supports. Many children and families who currently access NDIS-funded allied health supports are currently and will continue to be removed from the Scheme and redirected into systems that are not yet fully designed, funded, staffed or operational. This creates a transition risk.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 2146
If NDIS Access Narrows Before Foundational Supports and Thriving Kids Pathways Are Ready…
Children and Families May Experience Service Gaps, Delayed Intervention,…
Early Support Is Not Simply A Cost. It Is Prevention And Capacity-Building Investment. For Many Children…timely Allied Health Interventions Supports Communication Regulation Participation School Readiness Family Confidence Inclusion…. Concerns:
- Assessment & Planning Must Retain Professional Judgement: The bill appears to increase reliance rules frameworks tools administrative mechanisms in planning decisions Functional capacity cannot understood properly through blunt categories alone Good assessment requires professional judgement context observation clinical reasoning understanding how disability affects daily life across environments This particularly important children people with communication needs psychosocial disability fluctuating conditions complex family contexts or needs not easily captured standardised tools Tools can support decision-making should replace skilled assessments Any use automation algorithms standardised assessment must include human oversight transparent review pathways meaningful input appropriately qualified allied health professionals
- Workforce Provider Viability Must Be Considered The NDIS does operate isolation workforce delivers it Allied providers already facing rising wages, shortages burden costs pressure reform uncertainty Private community-based businesses employ clinicians train graduates deliver services local communities carry infrastructure quickly lost Profession remain accessible if employing that profession become unviable. Provider viability participant outcomes considered together
- Small Business Impact Workforce Migration Risk: Bill also be considered lens of allied business ownership Significant proportion allied health services delivered by small medium private providers These are large corporate entities deep reserves Local carrying payroll leases supervision compliance obligations graduate development governance unpaid administration increasing risk Pricing access eligibility funding changes reduce service demand commercially make delivery unviab impact will limited owners flow directly employees contractors participants families and communities Real risk reform unintentionally destabilises the Scheme relies on
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2146
When small, allied health businesses close, downsize or withdraw from NDIS work, clinicians do not simply remain available in the same locations and service models. They may move to hospitals, education, aged care, insurance, private-pay services, larger NGOs, government-funded roles or leave the sector altogether. This workforce migration risk is serious. It may reduce participant choice, weaken local service access, lengthen waitlists, reduce early intervention capacity and remove experienced clinicians from the disability ecosystem. It may also disproportionately affect regional and outer-suburban communities where small providers are often core service infrastructure. Government cannot assume that if one provider exits, another will simply appear. Allied health businesses hold community relationships, clinical knowledge, referral pathways, supervision structures and service capacity that take years to build. Once lost, this infrastructure is difficult and expensive to recreate. A sustainable NDIS requires a sustainable private allied health provider workforce.
Concern 7: Gendered Impact On Women-Owned Businesses And Workforce
There is also a gendered impact that must be recognised. Many allied health businesses are women-owned and women-led. The allied health workforce is heavily female, and many business owners are also working mothers, carers, regional employers, sole traders, or clinicians who have built flexible businesses around professional, family and community responsibilities. Some business owners and clinicians are also people with disability themselves. Reform that destabilises provider viability may therefore disproportionately affect women business owners, women employees and women with disability who have built businesses and careers within the disability sector. This impact is not incidental. If small and medium allied health businesses close, downsize or withdraw from NDIS work, the consequences will flow through a predominantly female workforce. Jobs may be lost. Hours may be reduced. Career pathways may narrow. Graduate supervision may decline. Flexible employment options may disappear. Women-led local businesses may be pushed out of markets they helped build. The Bill should therefore be considered not only as disability reform, but also as small business, workforce and gender equity policy. A sustainable NDIS should not be achieved by unintentionally transferring financial, operational and emotional cost onto women-owned businesses and a predominantly female allied health workforce.
Concern 8: Moral Injury And Trust In The System
There is a significant moral injury risk in these reforms. Participants, families, clinicians and ethical providers are being asked to absorb the consequences of years of system design failure, inconsistent stewardship, poor market settings and inadequate integrity controls. Many providers have worked in good faith within the rules and pricing structures set by government. Many participants and families have relied on supports that were assessed, funded and approved through the Scheme. If reform is experienced primarily as sudden cuts, reduced access and weakened continuity of care, trust in the system will deteriorate further.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 2146
The government has responsibility carefully reforming this scheme while protecting people from bearing costs due to past mismanagement that undermines safety, dignity, long-term outcomes.
Practical Implementation Risks
Implementation timetable requires extreme caution: The budget resets proposed begin October 1st of social/civic/community participation capacity-building daily activities with further planning system changes following.
Participants/families/providers/planners have compressed period understand reforms adjust supports manage transitions avoid service disruption without clear guidance transparent communication adequate transition arrangements may create confusion rushed decision-making inconsistent interpretation unavoidable harm.
Recommendations
Nacre Consulting recommends Parliament amend/constrain bill ensure improvements sustainability without undermining participants’ outcomes/workforce trauma private allied healthcare business continuity or service discontinuity:
- Protect individualised clinically informed decision making: The bill should be amended funding decisions remain based on individual functional need not broad class-wide reductions alone use assessment tools algorithms standard frameworks require human oversight transparency reasoning review rights input appropriately qualified allied health professionals;
- Delay stage reduction until alternative support operational Reduces capacity building/participation/early intervention-related supports proceed ahead fully designed funded and operational alternatives such foundational Thriving Kids pathways Transition arrangements explicit-funded-monitored for gaps services;-
- Establish formal Allied Health implementation advisory mechanism: Government establish time-limited group including participants families private providers community clinicians owners peak bodies advise design pricing provider viability workforce impact early childhood quality safeguards risks implementations. ; -
- **Undertake small business work force impact assessment Before implementing funding reductions major access changes government undertake publish small business and allied health workforce impact assessment examine likely effects provider viability migration regional women-owned businesses employment graduate supervision participant choice .;- 5 Protect Provider infrastructure during transition
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 2146
Government should develop transition arrangements that protect established allied health provider infrastructure while foundational supports, Thriving Kids and any commissioned models are designed and implemented. This should include clear communication, staged implementation, provider consultation and mechanisms to prevent unavoidable workforce loss.
Examine and report on administrative efficiency
Before reducing participant supports, Government should identify, measure and report on administrative inefficiencies within the NDIS and broader Scheme administration. This should include duplication, planning delays, internal rework, dispute costs, inconsistent decision-making, poor communication, fraud detection gaps and avoidable bureaucratic churn.