Submission 227

NDIS Submission: Frontline Provider and Family Perspective

Tracey Sutton

Introduction

I have worked in the disability sector for over 20 years across both clinical and service delivery roles, and I have never seen the level of distress, confusion, and burnout that is currently evident across families, clinicians, and providers.

In my current role supporting participants and managing a small-to-medium provider delivering day-to-day services, I am seeing firsthand how recent changes are impacting access to essential supports. As well as business providers, like me are trying to navigate changes constantly not knowing what the future holds. Many providers that we work along side are now either or looking to merge businesses for sustainability or leave the industry completely due to paperwork and justifying everything – their professions being ignored by planner and the NDIS.

This submission is provided in response to the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. The issues outlined below directly relate to proposed changes to participant eligibility, the definition of reasonable and necessary supports, funding decision-making processes, and expanded administrative and compliance powers within the NDIS.

From a frontline perspective, these changes have significant implications for how supports are approved, reduced, or withdrawn, as well as how participants and providers interact with increasingly complex administrative and review processes.

What is happening on the ground is not simply about “tightening the system” or improving sustainability. It is fundamentally changing how people access essential supports — and not for the better. While I fully acknowledge that the NDIS requires reform, the constant shifts in direction are creating significant uncertainty, and the reduction of essential supports is becoming increasingly apparent.

From direct frontline experience with 4000 + NDIS participants though our NDIS registered practice over 10 years and hearing all stories good and bad I honestly believe that — both clinically and operationally — there are many practical and achievable changes that could deliver meaningful outcomes for participants while also generating substantial cost savings for the NDIS. However, smaller to medium providers, those of us embedded in daily service delivery, often with 20–30 years of experience, are rarely consulted.

This raises an important question: why is the expectation that providers and participants must “reach in and hope to be heard” rather than government proactively reaching out to those with consistent, on-the-ground insight? Participants with cognitive capacity being heard, those without the ability to speak for themselves have to rely on others - advocates, carers and parents, but they are just too burnt out, time poor, broke and rejected to try fight the system for what is needed.

For the past 18 months things have become progressively worse. Families are increasingly being pushed into crisis, or into tribunal processes, in order to secure basic, clinically appropriate supports. In my own experience, this is no longer the exception, it is becoming the common pathway. At the same time, experienced clinicians are spending hours more time justifying supports than delivering them.

This has a direct impact on service capacity, staff retention, and ultimately the quality-of-care participants receive.

This submission reflects what is happening in real time across the sector. The following sections outline key issues and practical recommendations for reform.

Submission 227

Key Issues Observed Across the Sector

Across the sector, several consistent and concerning patterns are emerging:

• Reduction or removal of essential supports and equipment with or without adequate clinical justification.
• Increased administrative and reporting burden on clinicians.
• Delays and inconsistencies in decision-making.
• A growing disconnect between policy purpose and real-world implementation.

These issues align with proposed changes in the Bill that expand administrative and decision-making powers, which without sufficient clarity and consistency, risk increasing variability in funding outcomes and access to supports.

Impact on Participants and Families

Participants and their families are experiencing increasing levels of stress, instability, and uncertainty. Many families are now required to:

• Repeatedly advocate for supports that were previously considered reasonable and necessary.
• Navigate complex review and appeals processes.
• Manage gaps in services while awaiting decisions.

In our day-to-day work, we are increasingly seeing participants experience regression or stalled progress due to delays or reductions in previously recommended supports.

This is resulting in:

• Escalation into crisis situations.
• Deterioration in participant functioning.
• Increased reliance on emergency or higher-cost interventions.
• Participants receiving NDIS planning letters quoting: “the current support level is not considered as reasonable and necessary as per s34 (c) & (d) of the NDIS Act 2013.” Yet these supports have been in place for years and are essential for daily living.
• Often the participants that have received adequate levels of support for many years under the NDIS (and state services prior too, now to be stripped of their essential supports.

These issues are not isolated, they are widespread and are having significant impacts on participants, families, and providers alike.

Real Life Example Scenario 1

A participant in his 50’s who is non mobile (assisted wheelchair user) with fully cognitive capacity and verbal in communication, his relies on 2:1 hoist transfer to get out of bed each day and complete all personal care. He requires 1:1 support to drink, eat and access the community.

This participant, due to the NDIS no longer seeing his supports as “reasonable and necessary”, is only able to employ supports mornings and evenings. He remains in bed in his soiled incontinence aids from 7pm until 8am when staff arrive on shift and he is unable to access food or fluids in this time.

Around 8am, he is hoisted to his wheelchair, fed, cleaned, dressed, appointments completed before his carers’ shift ends around 11am. He will then sit in his wheelchair throughout the day (unless to tired to do so) and await carers to arrive back on shift around 3-4pm when the morning patter is reversed until he is hoisted into bed once again and his carers leave around 7- 8pm. This is what the NDIS sees is reasonable and necessary. It is NO way to live, and now he suffers from added mental health!

Submission 227

Real Life Example Scenario 2

A young participant who had been making slow but consistent progress with early intervention supports in multiple areas. They have recently had their therapy hours reduced at plan review, despite clear clinical evidence of ongoing needs, as the NDIS has noted the participants goals not being achieved as fast as the NDIS would expect and therefore the supports are “not reasonable and necessary at this time”.

Within months, this child has regressed in key functional areas, requiring increased behavioural support and additional specialist input. What was previously a stable, lower-cost support plan has now escalated into a more complex and significantly more expensive support arrangement with a plan review being requested, to then be rejected with the only option left being to escalate to the tribunal.

With current tribunal wait times, it is likely this participant will go without adequate supports for 6 months to a year minimum. With the current level of regression, these support costs are only going to increase the longer the wait.

As you can see in the context of the Bill’s proposed changes to eligibility and the interpretation of “reasonable and necessary” supports, these impacts may become more pronounced, particularly for participants with complex or evolving needs.

3. Impact on Clinicians and Providers

Clinicians are increasingly unable to focus on their primary role — delivering therapeutic and support services.

Instead, a significant portion of time is spent on:

• Writing extensive reports to justify supports.
• Responding to repeated requests for additional evidence.
• Managing reviews, reassessments, and appeals, which only cost the provider or the NDIS or both more in time and revenue.

Within our own team, a higher proportion of allotted clinician time is now allocated to report writing, reviews, and justification processes rather than direct therapy.

This is leading to:

• Workforce burnout.
• Reduced service capacity.
• Difficulties retaining experienced clinicians.

For small and medium providers, these pressures are becoming unsustainable.

The Bill’s increased focus on compliance, evidence requirements, and administrative oversight is likely to further shift clinician time away from direct service delivery, unless deliberate efforts are made to streamline these processes.

Example Scenario

Within our disability health service, clinicians are now routinely required to produce extensive documentation to maintain or secure supports that were previously considered standard.

This has resulted in reduced appointment availability, as clinicians spend increasing amounts of time on administrative requirements rather than delivering therapy. 1-2 hours of personal support can amount to a 3-4-hour report to justify the participants requirements. It was not, and should not be that hard.

Submission 227

Over time, this is limiting participant access to services while contributing to staff fatigue and burnout. Staff now feeling like lawyers advocating for their participant rather than helping them.

Lack of Genuine Consultation

There appears to be a significant gap in consultation with frontline providers.

Small and medium providers:

• Deliver a substantial proportion of direct supports.
• Hold extensive practical knowledge of participant needs.
• Have strong insight into cost-effective service delivery.

Providers of our size represent a substantial portion of the workforce delivering direct supports, yet our insights are often underrepresented in formal consultation processes.

This imbalance results in reforms that do not fully reflect operational realities. This is particularly critical given the Bill’s introduction of broad systemic reforms, where the absence of frontline input risks unintended consequences at the implementation level.

Cost Implications

Current approaches are not achieving system efficiencies and in many cases may be increasing overall costs.

From an operational perspective, we are seeing that time spent on administrative compliance is significantly reducing billable service delivery, which creates inefficiencies not only for providers but across the broader system. We keep hearing of providers making a fortune, but we service hundreds of participants annually and barely make a profit – so who is making the money?

The NDIS is also forgetting the return on every dollar spent effectively under the NDIS to Australia economy.

Key cost drivers include:

• Delayed or reduced early intervention leading to higher long-term needs.
• Increased administrative burden reducing service capacity.
• Growing reliance on tribunal and appeals processes.

The increasing use of tribunal processes has significant cost implications across all levels of the system:

• For the NDIS and government: legal representation, administrative processing, and tribunal resources.
• For providers: extensive unpaid/paid time preparing documentation, reports, and participating in proceedings, reducing time spent with other participants or said participant.
• For participants and families: emotional stress, time burden, and, in some cases, significant out-of-pocket expenses.

In some cases, these costs are substantial and disproportionate to the supports being sought.

While the Bill seeks to improve long-term sustainability of the NDIS, current implementation patterns suggest that without careful calibration, these changes may shift costs rather than reduce them, particularly through increased tribunal use, administrative burden, and delayed intervention.

Example Scenarios

We are increasingly seeing families required to pursue formal reviews or tribunal processes to secure supports that were clearly recommended from the outset.

Submission 227

In one case, a family spent months navigating internal processes before escalating to tribunal to obtain clinically appropriate supports. During this time, the participant went without essential services, resulting in increased needs.

In another case, a family incurred approximately $30,000 in legal fees in order to pursue appropriate supports through the tribunal process. This process created unnecessary stress for the family, delayed intervention, and introduced additional legal and administrative costs to the NDIS and family personally, this case is still not resolved 12 months later.

In addition to this financial burden, multiple treating clinicians were required to prepare detailed reports and attend proceedings to present evidence that had already been clearly documented. This resulted in significant time diverted away from service delivery and increased system-wide cost and inefficiency.

In another case a participant who had daily supports refused due to change of circumstances (near end of life) and needing higher supports was dragged to the tribunal. Her consumables quote for $2000 was then also questioned and the health professional dragged into 2 days of a 6-day tribunal hearing – all to dispute a $2000 quote for essential continence care as a result of a decline in health due to disability that is clearly evident.

Recommendations for Reform

The following are practical changes that, from a frontline perspective, would make a significant difference to both participant outcomes and the sustainability of the NDIS:

6.1. Improve Consistency and Transparency

There needs to be far greater consistency in how decisions are made.

• Provide clearer guidance for all – participants, providers and “IA planners!!”
• The NDIS needs “real life” guidance on deciding what is considered “reasonable and necessary” so participants and providers know what to expect and it is actually “reasonable, necessary and fair”.
• Ensure planning decisions better reflect clinical recommendations.
• Reduce the variation we are currently seeing between participants with very similar needs.

At the moment, outcomes are too inconsistent, which is creating confusion, additional workload, and unnecessary appeals.

6.2. Reduce Administrative Burden

The current level of reporting and justification is not sustainable.

• Streamline reporting requirements and reduce duplication, the NDIS will save thousands per participant here alone.
• Accept standardised reports rather than requesting repeated or slightly different information.
• Avoid requiring re-justification of supports where there has been no significant change in need.
• Respect the professionals who present their findings and recommendations.

Clinicians should be spending their time delivering services, not constantly rewriting reports to say the same thing.

6.3. Strengthen Early Intervention

We need to stop cutting supports early only to spend more later.

• Support early intervention properly and consistently.
• Recognise that reducing supports too early often leads to regression.
• Factor in the long-term cost savings when making funding decisions.

Submission 227

We know, short-term reductions are leading to higher long-term costs especially with those with mid to low level cognitive abilities.

6.4. Improve Consultation with Frontline Providers

There needs to be genuine engagement with providers actually delivering the work.

• Actively seek input from small and medium providers.
• Involve frontline clinicians in policy development and implementation discussions.
• Recognise that those delivering services daily have critical insight into what works and what does not.

Right now, the people with the most practical experience are often not being heard.

6.5. Reduce the Need for Tribunal

The current reliance on tribunal is a sign the system is not working as intended, and its only getting worse week by week with our practice alone being notified of 5+ families now heading to tribunal each week.

• Improve the quality and consistency of initial decisions.
• Strengthen internal review processes so issues are resolved earlier.
• Provide clearer explanations for decisions to reduce confusion and escalation.

Families should not have to go to tribunal to access supports that are clearly clinically appropriate.

7. Closing Statement

The NDIS is a vital system with the potential to deliver life-changing outcomes for participants and families. However, current changes are creating unintended consequences that are being felt across the sector.

By working more closely with frontline providers and focusing on practical, evidence-informed reform, it is possible to improve outcomes while ensuring long-term sustainability. Change is needed that is acknowledged.

Ensuring these reforms are informed by frontline and personal experience will be critical to achieving the Bill’s intended outcomes without compromising access, quality, or system efficiency.

We have great ideas; they just need to be heard. I, many other service providers, participants and parents are here just hoping someone will hear us. We would openly welcome ANY consultation.