Submission: Concerns Regarding Proposed Amendments to the NDIS Legislation Bill

To Whom It May Concern, I am writing to express my deep concerns regarding the proposed changes to the National Disability Insurance Scheme (NDIS) legislation bill. As someone who is deeply invested in the wellbeing and rights of individuals who rely on the NDIS, I believe it is crucial to address the potential implications of these changes. It is my hope that this submission will contribute to ensuring that the NDIS remains a fair, effective, and person-centred system that upholds the dignity and needs of all participants.

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

Submission 2166

These nuances cannot be captured through self-reporting alone. Furthermore, allied health professionals bring a deep understanding of medical conditions and their varied presentations, which allows us to ask targeted questions and identify issues that may not be immediately apparent. For example, we understand how different environments can exacerbate symptoms—such as how a person’s mobility or behaviour may differ in the safety of their home compared to a public space like a shopping centre. Using the I-CAN assessment as the sole tool to determine eligibility for NDIS support is not only inadequate but also ethically indefensible. It risks denying vulnerable individuals the support they need based on incomplete or inaccurate information.

Rigid Budgeting Structures and the Need for Flexibility The proposed structure of NDIS budgets is inflexible and fails to account for the dynamic and individualised nature of participant needs. As a specialised OT working in home modifications (HM), I have witnessed firsthand how rigid budget categories can hinder participants’ ability to access the most appropriate and cost-effective supports. For example:

• Home Modifications vs Assistive Technology (AT): In some cases, a one-off investment in home modifications can eliminate or significantly reduce the need for ongoing AT costs; Conversely, in other cases prioritising AT may reduce the need for costly home modifications.The current structure does not allow for this kind of flexibility forcing participants to fit their needs into predefined categories rather than tailoring budgets to their unique circumstances Short-Term Respite:In the context of home modifications short-term respite may be necessary to allow construction work to be completed safely However it may not be required.Budgeting should reflect these individual variations rather than imposing an onesizefitsall approach Behaviour Support Plan Management These funds also need ebb flowbasedontheparticipant’s changingneeds A rigid allocation system fails accommodate realityA flexible budgeting model essential ensure that participantscanaccessthesupportstheyneed when they need them without being constrained by arbitrarycategories.

Barriers to Accessing “Appropriate” TreatmentThecurrentsystem’sdefinitionof“appropriate”treatmentisdeeplyflawed The proposed amendment states treatment still considered

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

Submission 2166

If treatment is deemed “appropriate,” funding, accommodation, and support must be provided to to ensure that participants can access it. Anything less is unjust and reflects a lack of understanding of the lived realities of those who rely on the NDIS.

Tightening “Reasonable and Necessary” Criteria

The push to tighten the “reasonable and necessary” criteria by prioritising comparable supports at lower cost fails to consider the functional outcomes for participants. For example:

• A shower stool without armrests or back may be an alternative low-cost option compared to chair with arms and back; however individuals requiring further assistance find stools unsafe unusable necessitating grab rails—a far more expensive solution long term. Cost-cutting measures prioritize short-term savings over longer-term participant safety quality life counterproductive compromising risk compromise. This proposal includes same outcome comparison needed.

Maximum Funding Intensity Staffing Ratios

A one-size-fits-all approach budgeting specific diagnosis harmful ignores diverse needs individual medical conditions vary greatly between people level required depends circumstances instance person cerebral palsy need intensive care another occasional mobility assistance Blanket caps rigid staffing ratios based diagnosis leave inadequate support The NDIS base funding intensity staff ratio personalized assessments resources allocated fairly effectively Additionally symptoms year non-linear manner not considered.

Ministerial Powers Bias in Budgeting Capping

Increasing ministerial powers involvement raises significant concerns bias inequity decisions deemed reasonable necessary influenced political financial considerations rather actual needs participants This creates system where allocations evidence individual circumstance but shaped overarching budgetary constraints minister priorities Approach disproportionately impacts vulnerable populations particularly those from socio-economic backgrounds rural remote areas already disadvantage when accessing services also undermines integrity of by prioritizing containment over participant outcomes To address this issue third-party authority organization robust transparent design must used instead oversee budgeting capping decision should operate independently influence guided evidenced-based practices, participant needs ethical principles Such framework ensure fair equitable focused best possible outcomes for participants.

Amendment to Expectations Informal Supports

The expectation parents provide substantial care and support children with additional needs especially cut unrealistic dangerous Parents complex additional challenges providing adequate care expecting

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

Submission 2166

them to be the sole providers of these supports without adequate external assistance can lead to devastating consequences. A tragic example of this is the Mosman Park murder-suicide, where a family took extreme actions after being unable to cope with the demands of supporting their children with Autsim Spectrum Disorder following the reduction of vital support funding. This heartbreaking case highlights the critical need for additional support for families of children with disabilities. Cutting funding for these families not only jeopardises the wellbeing of the children but also places additional burnout, stressors and financial strain on parents.* Many families may be forced to rely more heavily on government subsidies and payments,* as one or both parents might have needed to give up work to provide full-time care*. This isn’t an ethical solution* or sustainable. Children requiring extra needs require further support*, which typical nuclear-family structures are simply incapable of providing alone . The NDIS must recognize that reality ensuring its decisions reflect genuine familial needs rather than imposing unrealistic expectations risking further harm* .

Effective and Beneficial Supports

The current reliance upon high-level published research as primary evidence in determining “effective” & beneficial“ support is fundamentally flawed.“ While such research matters greatly,“ it shouldn’t overshadow qualitative data—the lived experiences from individuals living within disability conditions and their respective households.“ Such imbalance requires rectification; quantitative studies often fail capturing complexities inherent when navigating life under a disability“, neglecting nuanced realities shaping individual requirements.” Lived experience offers crucial insights into practical application and real-world effectiveness, highlighting service gaps and barriers access ignored rigidly driven criteria risks creating disconnected systems those intended serve.“ The NDIS should adopt balanced approach valuing high-level research alongside equally important qualitative data enabling supports become evidence-based person-centred practical genuinely benefiting participants.

Addressing Systemic Issues Waste

While addressing inefficiencies budgeting necessary the current approach unfairly targets participants instead systemic issues other key areas review include:

• Unused Funds: Participants frequently spend allocated funds unnecessarily avoid losing them future funding reviews flaw system not fraud by participants.*
• Support Provider Reviews: Shonky coordinators approved businesses charging exorbitant rates need investigation held accountable permanent exclusion implemented these practices exploit divert funds away most needed.

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

Submission 2166

Conclusion

The proposed changes to the NDIS fail to adopt a person-centred approach, undermining the lived experiences of individuals with disabilities. By reverting to a mechanistic, one-size-fits-all model that focuses solely on medical conditions, these changes ignore consumer voices, fail to promote inclusivity, and risk further socially marginalising and isolating participants. Instead of making structural changes based on detached decision-making, policymakers should listen to the consumers—that those who use the scheme have first-hand experience of its flaws—before deciding what is best for them. Yours Sincerely,