NDIA Accountability Project

Concerns regarding changes to entry criteria and assessment processes

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Submission 2226

Submission to the Senate Community Affairs Legislation Committee.

CC Dr Jim Chalmers M P

Submitted by

29th May 2026.

Consent to publish without my name.

Dear Members,

About me.

Thank you for asking for submissions on the proposed new Act and takingthe time to read and consider our thoughts. We suggest possible alternatives to some of the items in the Amendment.

However, firstly I accept that the NDIS is a fantastic program initiated by the Australian parliament.

I also understand :

  • That the cost of the program is extremely high
  • That the cost is continually increasing
  • That each year the number of people accessing the scheme is increasing under the present guidelines
  • That the increasing costs will ultimately make this great scheme unsustainable
  • That changes to the entry criteria have to be made.

HOW THE CHANGES ARE MADE.

I have concerns about how the proposed changes are proposed to be made.Many changes are at the discretion of the Minister.This makes many criteria open to political philosophy at the time. With respect, this is completely unacceptable. Please , Include the health professionals who are at the workface in the decision making process.

Assessment .

Especially when a review of a person’s plan is conducted, it is conducted using question over the phone and the replies are fed into a set program on a computer. I see great similarities to ROBODEBT. Also the results are not made available to the person seeking the review. There is also a change to the time taken for a decision to be made. Now a decision has to be given in 21 days and it is proposed to have a decision given in 90 days.

Submission 2226

Often when unforeseen circumstance change during a plan, a decision is needed almost immediately. Having to wait 90 days is not in the best interest of the client.

As well, the new system will not approve a reassessment if it is not a permanent change to his/her condition. For example, parents are expected to be more involved in the care of the disabled person. If the parents are suddenly invalided or have to be absent for 3 weeks, it is proposed to deny a reassessment of a plan because it is not a permanent change. The system has to be changed to cope more with normal living conditions.

The Bill does not specify significant changes. These need to be specified to be clear for all concerned.

Parent’s Responsibilities.

At present ,the aim of the NDIS is to support a person with a disability to live as normal a life in the community as possible. Parents are not expected to supply transport , emotional support and assistance with daily tasks.

Changes appear to strengthen the NDIA’s argument that parents should provide high level of support in areas not directly caused by the disability. For example parenting, emotional support, behaviour management, transport and assistance with daily tasks. These are all facets that have their root cause in the disability. The wording of the Act needs to be changed to include support from outside the family circle. Elderly parents often can not supply the support that is needed and the new Act needs to cater for that.

Value for Money.

There is going to be a person in the department who looks at getting cheaper options. The new Act indicates that a computer will be researched to find a peer-reviewed opinion on the suitability of a cheaper option. The new criteria are taken from published journals. This is very selective and open to manipulation. The issue should be that we must get the SAME OUTCOME from the lower expenditure recommended by the peer reviewed literature. The decision should have primarily the regard for the participants circumstances. The new Act should reflect that.

Service Providers.

Submission 2226

The Amendment requires all service providers to be registered. That will make control efficient. A panel will set prices that the providers can charge. ( at the moment providers charge the top rate on the NDS list). If participants let it be known that it is an NDIS account, then the highest possible price is charged There needs to be a check that the prices are realistic.

Automated Decision Making. (ADM)

ADM is planned for Plan content, payments, claims, pricing and reviews of plans. Changes I propose include Human review of decisions especially adverse decisions before the decisions take effect so that the participant and any others can see the decision in order to agree or appeal.

Review of this Bill.

This Bill will have major changes for NDIS participants. To monitor the effects of these changes I suggest that the ACT has a legal requirement of an in depth review 24 months after commencement. There will be new functional capacity tests, new budget systems, new automated decision making procedures , new claims procedures, new replacement procedures and expanded ministerial powers just to name a few. It is near impossible to predict how everything will work out for participants. It is imperative that an independent in depth review in done within 24 months of inception to see how the scheme is working for all people involved.

To Conclude.

I ask the Committee and the Minister to remember that all the participants are people with varying levels of ability to operate in the NDIS system.

Please word this new Bill with that in mind. These people have extremely varied conditions and needs. Automated decision-making can save time and money but there has to be a transparent appeals process to cater if there is a different situation.

I wish the Committee wisdom and discernment when reading the multitude of ideas and suggestions presented in the submissions.

Submission 2226

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