Submission 2210
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Na#onal Disability Insurance Scheme Amendment (Securing the NDIS for Future Genera#ons) Bill 2026
SubmiBed by:
- Profession: Speech Pathologist - Date: 29 May 2026
A. Introduc#on
I am a Speech Pathologist with seventeen years of clinical experience across the non-government, public, and private sectors in NSW. I received my Bachelor of Applied Science (Speech Pathology) from the University of Sydney in 2009 and have been pracJsing full-Jme since then. I am a CerJfied PracJsing Speech Pathologist (CPSP) and member of The Speech Pathology AssociaJon of Australia Limited (Speech Pathology Australia).
I have been the Director and Senior Speech Pathologist at my private pracJce, ,
since 2015. provides assessment and treatment for communicaJon and swallowing (dysphagia) difficulJes in both children and adults. I was previously employed by and , and have worked as a Clinical Educator and Speech Pathologist at . I now provide clinical supervision to other speech pathologists and students. – and I rouJnely aUend professional development and training across a range of pracJce areas. I am currently compleJng a PhD at University, where my research focus is on the assessment of language disorders in children. These qualificaJons and experiences have given me extensive experience in the assessment and treatment of individuals with complex communicaJon needs, including children and adults with a range-of neurodevelopmental condiJons and disabiliJes.
Throughout my career, I have worked directly with people with disabiliJes and have witnessed first-hand the transformaJve impact the NDIS has had, not only in improving access to speech pathology services, but in enabling community parJcipaJon, mulJdisciplinary support, and the kind of person-centred, lifelong care that did not exist at this scale prior to the Scheme. I make this submission from the perspecJve of a pracJJoner who values the NDIS and wants to see it strengthened in a way that is effecJve and equitable.
B. Schedule 1, Part 8 — Tightening the meaning of permanence
This is the provision I am most concerned about, and I urge the CommiUee to scruJnise it carefully.
The Bill proposes to Jghten the definiJon of permanence so that where treatment can reduce
the impacts of an impairment, that impairment may no longer meet the permanence criterion for NDIS access. This reflects a fundamental misunderstanding of both the nature of disability and the purpose of therapy.
People can have permanent, disabling condiJons and sTll demonstrate meaningful improvement through treatment. As a speech pathologist, I work with clients whose underlying condiJons (e.g., acquired brain injury, cerebral palsy, degeneraJve neurological condiJons, Down syndrome, auJsm) will never "resolve". The purpose of therapy is not to eradicate these condiJons, but to improve the person's funcJonal capacity.
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Speech pathology services help those people communicate more effectively, eat more safely, and participate more fully in their lives. A child who learns to use an AAC device has not “lost” their disability. An adult whose swallowing improves with therapy is not “cured”. These improvements may sometimes be incremental and sometimes transformative, but in neither case do they erase the underlying condition or the ongoing need for support.
Further, defining disability based on responsiveness to intervention risks diminishing the identity of people within the disability community by drawing arbitrary links that may not reflect one’s lived experience or personal perspective of disability. Support needs may change over time, and research demonstrates the benefit of early and intensive intervention. Intervention supports can significantly reduce the well-documented long-term risks and harm that people with diagnosed disabilities may face. However, disability is lifelong, and individuals are likely to require supports (in changing form) across their lifespan.
The proposed framing conflates “treatable impacts” with “non-permanent impairment”. This is clinically and conceptually wrong. Under this logic, a person with a significant communication disability who makes meaningful gains through intensive therapy could face a revoked or reduced plan, effectively penalising both the person and the effective therapy that helped them. This creates a perverse incentive, where demonstrating improvement through therapy risks losing access to the very support that enabled it. This approach is inconsistent with the NDIS objective of supporting capacity-building and participation, and risks undermining Australia’s obligations under the UN Convention on the Rights of Persons with Disabilities, which recognises disability as evolving and interactive rather than eliminated through treatment.
I urge the Committee to reject or substantially amend this provision, and to ensure that the definition of permanence reflects the reality that disability is not static, and that therapeutic progress does not equate to the absence of disability.
C. Schedule 1, Part 9 — Eligibility based on access to other services
The assumption embedded in this provision, i.e., access to mainstream or community services constitutes adequate and equivalent support, does not reflect the reality I encounter in clinical practice.
The capacity of public health, education and community systems to support people with complex communication and disability-related support needs remains highly variable and often insufficient. Excluding individuals from the NDIS on the basis that they can “access” alternative services risks creating significant service gaps, rather than ensuring that their needs are met through other systems.
Redirecting people to those systems without substantially improving them will result in people going without support, not in people receiving equivalent support elsewhere. For support to be genuinely equivalent, there would need to be large-scale reform, including workforce expansion, specialised training, improved infrastructure, and the development of consistent quality standards. These sectors have, in many cases, reduced their disability-specific capability over the past decade as responsibility has shifted toward NDIS-funded supports. Rebuilding this capacity cannot be assumed and will require significant time and resourcing.
This risk is particularly pronounced for individuals who have left the school system. Historically, adults with disability, especially those with complex communication and support needs, have been significantly underserved by mainstream systems outside of school-based supports. There is a substantial risk that, if eligibility is restricted on the basis of presumed access to mainstream services, this group will once again experience reduced access to appropriate supports, replicating pre-NDIS gaps in service provision.
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Further, the provision appears to rely on an implicit separaJoN of service systems such as health, educaJoN, community, and the NDIS that does not reflect the lived experience of people with disability. In reality, individuals oben require integrated, overlapping supports across these domains. TreaJng support needs as compartmentalised risks denying access to necessary services and failing to account for the interconnected nature of funcJo nal impairment and parJcipaTon needs.
Without clear safeguards, this provision risks excluding individuals from the NDIS on the assump Jo n that other systems will meet their needs, in circumstances where those systems are not currently equipped to do so.
I recommend that Schedule 1, Part 9 be amended to include explicit safeguards requiring decision-makers to be saJsfi ed that alterna J ve services are accessible, available in prac Je , and capable of delivering func Jonally equivalent and Jmely supports before access to the NDIS is denied on this basis. This assessment should incorporate the perspec J ves of people with lived experience of disability and their carers. ConsideraJon should also be given to the historical undersupply of services across the lifespan, to avoid re-establishing known service gaps. Meaningful consultaJon with advocacy organisa J ons, unions, and relevant peak bodies should also inform the development of Rules and implementaJon guidance in a genuine and ongoing way.
D. Schedule 1, Part 6 — Reasonable and necessary supports / Scheme sustainability
I note with concern the introduc Jo n of new secJo n 17B, which requires the CEO to have regard to the financial sustainability of the scheme when making individual support decisions. While flscal responsibility is important, embedding sustainability as a principle in individual funding decisions creates a risk that those decisions will be driven by cost-containment rather than individual need. CommunicaTon and swallowing supports are oben not easily quanJfi ed or immediately “effi cient” in a cost sense, yet they are founda Jo nal to safety, dignity, and quality of life. Linking scheme sustainability so directly to what is considered a “reasonable and necessary support” risks undermining clinical decision-making and leading to poorer long-term outcomes for parJcipants.
The new “value for money” provisions (proposed subsecJo ns 34(1A)–(1C)), which require the CEO to consider lower cost alterna J ves, must not result in parJcipants being systema J cally directed toward cheaper supports that are less clinically appropriate. In allied health, cost and clinical suitability are not the same thing. Further, the concept of “value for money” is not new within the NDIS framework.
E. Schedule 1 — Community pa r# pita # on supports
I understand that concerns about inadequate service quality among some community pa rJ pipa Jon providers have informed the proposed restric Jo ns in this area. However, removing or restric Jing access to community pa rJ pipa Jon supports on the basis that some providers deliver them poorly is the wrong response. It denies support to pa rJ pipants who need it, rather than addressing the quality of provision.
An appropriate response is improved regulaJon of providers, rather than denial of access. This is achievable. Mandatory, disability-specific training for support workers, combined with rouJne audiJng of providers, would address quality concerns directly. These audits do not need to be burdensome or costly for providers or for government. They can be designed as proporJo ne , risk-based processes that focus on key quality indicators without requiring excessive administraJve overhead.
The Australian Government has demonstrated, at both federal and state levels, that it can design and deliver effi cient, high-volume compliance systems when there is poli J cal will to do so. Service NSW’s approach to digital service delivery (e.g., centralised digital plajorms, streamlined transacJo ns, low-fricJon compliance processes, scalable systems, and minimal paperwork and admin burden for
Submission 2210
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users) and the rapid rollout of small business compliance and support systems during the COVID-19 pandemic are examples of government operaJng effecJvely at scale. There is no reason the NDIS Quality and Safeguards Commission could not operate a similarly streamlined, low-fricJon audit system for community parJcipaJon service providers and indeed, all NDIS service providers.
I urge the CommiUee to recommend that quality concerns in this area be addressed through strengthened provider standards and mandatory workforce training, rather than through restricJons on parJcipant access.
F. Schedule 2, Part 1 - Registra#on of NDIS providers
I support the intent of provider registraJon as a means of upholding minimum standards and reducing misuse. However, I have significant concerns about how the new definiJon of “NDIS provider” (proposed secJon 10C) and the associated registraJon framework will apply to small businesses and sole trader allied health pracJ Joners.
The Bill provides that classes of persons may be excluded from the NDIS provider definiTon by the NDIS Rules (s.10C(2)). I urge the CommiUtee to recommend that this power be used to create a proporJonate pathway for registered health professionals who already operate within robust accountability frameworks, including holding a Medicare provider number, current police checks, professional indemnity insurance, and membership of a recognised peak body such as Speech Pathology Australia. These pracJ Toners already meet the standards that registraJon is designed to ensure.
Requiring smaller providers to undergo a full NDIS registraRon process designed for large organisaJ ons will likely result in many experienced sole traders and small pracJ ces choosing not to register, directly reducing the pool of qualified providers available to parJcipants. It is not only the financial cost of registraRon that is prohibiJ ve, but also the Jme and administraJve burden, which a single-person pracJ ce simply may not be able to absorb. Reducing this pool of experienced and qualified providers, or creaJ ng a Jered pricing system to enforce mandatory registraRon that is costly and excessively Jme consuming, risks NDIS parJcipants losing access to high-quality services, and instead having to access providers with less experience, knowledge, and commitment to the field. Larger organisaJons can provide greater oversight and compliance, but smaller providers may offer more flexibility and individualised services. NDIS parJcipants should remain able to choose their service providers without unnecessary restricTon.
I recommend that the NDIS Rules developed under this Bill create a Jered or streamlined registraRon pathway for individual health professionals that recognises exisJng regulatory obligaJons. The compliance burden should be proporJonate to organisational scale. A sole-trader pracJce and an organisaJon of 250 staff should not face the same registraRon requirements.
G. Schedule 2, Part 4 - Reten#on of records
I support the requirement for NDIS providers to retain records relaJng to claims for payment (proposed secJon 45B). This is consistent with obligaJons most allied health professionals already meet under their professional registraJon requirements, and I have no objecjon to this provision.
H. Schedule 2, Part 5 - Reducing claim #mes
I support Jmely invoicing as a fraud-prevenJon measure. I recommend mandatory upload and verificaJon at Jme of service to reduce claim Jmes and ensure accuracy of claims.
Submission 2210
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e. Schedule 2, Part 6 — Registered plan management providers
I recognise that concerns about conflicts of interest in plan management have been raised, and that appropriate safeguards are important. However, plan management has played a criJcal role in enabling parJticant choice and flexibility, including allowing parJticipants to access services from non-registered providers. It has also supported the development of a substanJal workforce and service ecosystem, with associated economic benefits.
Any new requirements, including deed of arrangement provisions (proposed secJons 73EA and 73EB), should be implemented in a way that maintains the accessibility and flexibility that plan management currently provides. Improved regulaTon and audiJng of plan management providers can be used to minimise risks whilst avoiding unnecessary disrupJon to parJticipants’ access and the broader workforce.
e. Conclusion
The NDIS has delivered real and lasJing benefit to Australians with disability, and to the professionals and communiJes that support them. The goal of securing it for future generaJons is one I share. That goal is best achieved through targeted, proporJonate measures that address genuine fraud and quality concerns, not through compliance frameworks that drive qualified providers out of the Scheme.
Most importantly, eligibility restricJons that misrepresent the nature of disability, or reduce access to therapeuJc support, community parJcipaJon, and quality of life, risk undermining the core purpose of the NDIS. I ask the CommiUee to ensure that the NDIS Rules and implementaJon guidance developed under this Bill reflect these realiJes, and that the voices of people with disability and frontline pracJjoners are central to that process.
Yours sincerely,
Director and Senior Speech Pathologist