Submission 2146

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

to: Senate Community Affairs Legislation Committee 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, expand administrative decision-making powers, and reshape access to capacity-building and participation supports.

These changes may have significant practical consequences for participants, families, allied health providers and the workforce delivering ndis services.

Our submission focuses on how the bill may affect individualised support, early intervention, provider viability, workforce sustainability, assessment quality and the service infrastructure needed to keep the scheme effective.

Position

Nacre consulting is conditionally supportive of reform that improves the sustainability, integrity and long-term viability of the ndis.

The scheme must be protected for current and future participants. There is a legitimate need to address fraud, poor- quality service delivery, inconsistent planning and unsustainable cost growth.

However, several elements of the bill risk creating serious unintended consequences if implemented without stronger safeguards.

The proposed changes may be intended to improve sustainability, but they also carry risks for functional outcomes, early intervention, participant independence, family capacity, workforce stability and provider viability.

The concern is not reform itself.

The concern is reform that reduces access to capacity-building supports before alternative systems are ready, relies too tightly on broad funding rules, and weakens the provider workforce needed to deliver safe, effective and outcomes- focused support.

What The Reforms Get Right

The ndis needs stronger integrity settings.

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.

Submission 2146

If NDIS access narrows before Foundational Supports and Thriving Kids pathways are ready, children and families may experience service gaps, delayed intervention, reduced continuity of care and increased pressure on schools, early childhood settings and families.

Early support is not simply a cost. It is a prevention and capacity-building investment.

For many children, timely allied health intervention supports communication, regulation, participation, school readiness, family confidence and inclusion. If access is reduced before alternative pathways are functional, the impact will be felt in homes, classrooms, clinics and communities.

Concern 4: Assessment And Planning Must Retain Professional Judgement

The Bill appears to increase reliance on rules, frameworks, tools and administrative mechanisms in planning and funding decisions.

Functional capacity cannot be understood properly through blunt categories alone.

Good assessment requires professional judgement, context, observation, clinical reasoning and an understanding of how disability affects daily life across environments. This is particularly important for children, people with communication needs, psychosocial disability, fluctuating conditions, complex family contexts or needs that are not easily captured by standardised tools.

Tools can support decision-making. They should not replace skilled assessment.

Any use of automation, algorithms or standardised assessment tools must include human oversight, transparent review pathways and meaningful input from appropriately qualified allied health professionals.

Concern 5: Workforce And Provider Viability Must Be Considered

The NDIS does not operate in isolation from the workforce that delivers it.

Allied health providers are already facing rising wages, workforce shortages, administrative burden, compliance costs, pricing pressure and reform uncertainty.

Many private and community-based allied health businesses employ clinicians, train graduates, deliver services in local communities and carry infrastructure that cannot be replaced quickly if lost.

A profession cannot remain accessible if the businesses employing that profession become unviable.

Provider viability should not override participant outcomes. But participant access and provider sustainability must be considered together.

Concern 6: Small Business Impact And Workforce Migration Risk

The Bill must also be considered through the lens of allied health business ownership.

A significant proportion of allied health services in the NDIS are delivered by small and medium private providers. These are not large corporate entities with deep reserves. They are local businesses carrying payroll, leases, supervision costs, compliance obligations, graduate development, clinical governance, unpaid administration and increasing reform risk.

If pricing, access, eligibility and funding changes reduce service demand or make delivery commercially unviable, the impact will not be limited to business owners. It will flow directly to employees, contractors, participants, families and communities.

There is a real risk that reform un/intentionally destabilises the workforce the Scheme relies on.

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.

Submission 2146

The government has a responsibility to reform the Scheme carefully, but also to protect people from bearing the cost of past mismanagement in ways that undermine safety, dignity and long-term outcomes.

Practical Implementation Risks

The implementation timetable requires extreme caution.

Budget resets for social, civic and community participation and capacity-building daily activities are proposed to begin from 1 October 2026, with further planning and system changes to follow.

This creates a compressed period for participants, families, providers and planners to understand changes, adjust supports, manage transitions and avoid service disruption.

Without clear guidance, transparent communication and adequate transition arrangements, the reforms may create confusion, rushed decision-making, inconsistent interpretation and avoidable harm.

Recommendations

Nacre Consulting recommends that Parliament amend or constrain the Bill to ensure reform improves sustainability without undermining participant outcomes, workforce trauma and private allied health business viability or service continuity.

1. Protect individualised, clinically informed decision-making

The Bill should be amended to ensure funding decisions remain based on individual functional need, not broad class-wide reductions alone.

Any use of assessment tools, algorithms or standardised frameworks should require human oversight, transparent reasoning, review rights and input from appropriately qualified allied health professionals.

2. Delay or stage reductions until alternative supports are operational

Reductions to capacity-building, participation or early intervention-related supports should not proceed ahead of fully designed, funded and operational alternatives such as foundational supports and Thriving Kids pathways.

Transition arrangements should be explicit, funded and monitored for service gaps.

3. Establish a formal allied health implementation advisory mechanism

Government should establish a time-limited allied health implementation advisory group including participants, families, private providers, community providers, clinicians, business owners and peak bodies.

This group should advise on assessment design, pricing, provider viability, workforce impact, early childhood transition, quality safeguards and implementation risks.

4. Undertake a small business and workforce impact assessment

Before implementing funding reductions or major access changes, Government should undertake and publish a small business and allied health workforce impact assessment.

This should examine likely effects on provider viability, workforce migration, regional access, women-owned businesses, employment pathways, graduate supervision and participant choice.

5. Protect provider infrastructure during transition

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 avoidable 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.

Conclusion

The NDIS must be sustainable.

It must also remain individualised, evidence-informed and capable of delivering real functional outcomes for people with disability.

Reform should strengthen the Scheme, not narrow it in ways that shift cost and harm onto participants, families, clinicians and ethical providers.

The Bill should be amended to protect individualised assessment, retain professional judgement, avoid premature reductions before alternative systems are ready, examine administrative efficiency before reducing supports, and recognise the allied health workforce and provider infrastructure required to deliver the Scheme safely into the future.

Cathy Love

CEO Nacre Consulting Pty Ltd

P.O. Box 238 Blairgowrie

Victoria 3942