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, such like me we’re trying to navigate constant change not knowing where things will lead next year or even month after another. Many other providers with whom you work alongside now either merge businesses together out of necessity due to paperwork overload or leave entirely because their professions being ignored by planner and the NDIS. The submission provided here responds directly National Disability Insurance Scheme Amendment (Securing the NDIS) Bill 2026. Issues outlined below relate proposed changes participant eligibility definition reasonable necessary support funding decision-making processes expanded administrative compliance powers within NDLS. From front line perspective these changes significant implications on whether supports approved reduced withdrawn also interact increasingly complex admin review process ground happening simply about tightening system improving sustainability fundamentally changing people accessing essential supports better fully acknowledge requires reform but constant shifts direction creating significant uncertainty reduction essential supports becoming apparent direct frontline experience +4k+NDIS participants though our registered practice over decade hearing all stories good bad honestly believe both clinically operationally many practical achievable changes could deliver meaningful outcomes for participants while generating substantial cost savings for NDLS however smaller medium providers those embedded daily service delivery often years experienced rarely consulted raises important question expectation that providers must reach hope heard rather than government proactively reaching out consistent, grounded insight Participants cognitive capacity being heard others - advocates carers parents just too burnt time poor broke rejected fight needed past months things become progressively worse families pushed crisis tribunal processes secure basic clinical appropriate supports own experience this exception common pathway same time clinicians spending hours more justify delivering them has a direct impact services staff retention quality-of-care received reflects real-time sector following sections outline key issues and recommendations

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

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. The issues align with proposed changes that expand powers which risk increasing variability if not clarified consistently: funding outcomes access to support.

Impact On Participants And Families

Participants families experiencing stress instability uncertainty many families require repeatedly advocating previously considered reasonable necessary navigate complex review appeals processes manage gaps services while awaiting decisions In our day-to-day work participants experience regression stalled progress due delays reductions recommended supports resulting crisis situations deterioration functioning increased reliance emergency higher-cost interventions participants receiving letters quoting current level as per s34(c)(d) NDIS Act yet these have been years daily living often received levels under NDIS state services prior stripped their essential supports These isolated widespread significant impacts participant family providers alike Real Life Example Scenario1 Participant his non mobile assisted wheelchair user fully cognitive capacity verbal communication relies hoist transfer get out bed complete personal care requires one-on-one drink eat community This no longer seeing supports “reasonable” only able employ mornings evenings remains soiled aids from 7pm until when staff arrive shift unable food fluids time Around am he is hoisted wheel chair fed cleaned dressed appointments completed before carers’ ends around pm He will sit throughout the day unless tired do await back shifts around -am morning pattern reversed until once again carers leave about NO way live now suffers added mental health!

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

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 participant’s goals not being achieved to fast enough according to what they expect; hence it is deemed “not reasonable and necessary” currently.

In months’ span this child regressed significantly across key functional domains requiring increased behavioral support alongwith additional specialist input. The once stable lower-cost care arrangement now escalated into more complex arrangements necessitating further reviews which were rejected leading them towards tribunal escalation due to current wait times exceeding six-months minimum or even longer if regression continues; these costs will rise as time passes without adequate support. As seen within context provided regarding proposed changes under eligibility criteria & interpretation on ‘reasonable necessity’, such impacts may become pronounced especially among participants having evolving complexities.

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

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:

• Delivering a substantial proportion of direct supports,
• Holding extensive practical knowledge of participant needs,
• Having strong insight into cost-effective service delivery. Providers of our size represent a substantial portion of the workforce delivering direct supports; yet we often underrepresent ourselves during consultations due to an imbalance resulting in reforms not fully reflecting operational realities given broad systemic reform introduced within the bill where absence of input risks unintended consequences at implementation level.

Cost Implications

Current approaches aren’t achieving system efficiencies as they may increase overall costs instead through inefficiencies created when administrative compliance reduces billable service delivery which impacts both provider profitability across broader systems alike. The NDIS also overlooks return on every dollar spent effectively under it towards Australia’s economy by neglectful oversight. Key cost drivers include:

• Delayed or reduced early intervention leading higher long-term needs;
• Increased administrative burden reducing capacity;
• Growing reliance upon tribunal appeals processes. Increasing use tribunals has significant implications throughout all levels impacting: For the NDIS & government: legal representation, processing admin., resources for tribunals. For providers: extended unpaid/paid time preparing documentation reports participating proceedings thereby decreasing interaction w/ other participants/families involved. Participants and families face emotional stress increased time burdens some cases even out-of-pocket expenses incurred. In many instances these costs are disproportionate relative actual support sought. While Bill seeks improve sustainability over longer term without careful calibration changes could shift costs rather than reduce them particularly via increasing tribunal usage, heightened administration demands delayed interventions.

Example Scenarios

We increasingly see families required to pursue formal reviews/tribunal procedures securing supports clearly recommended from outset.

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

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 unresolved after twelve months of proceedings.*

In addition to these financial burdens*, multiple treating clinicians were required to prepare detailed reports and attend hearings to present evidence already clearly documented*. This resulted in significant diversion away from service delivery* due to inefficiency,* increasing system-wide costs, time wasted on unproductive procedures,** which ultimately led to higher expenses*** than necessary**** due***** to inefficient practices****** that should be addressed******* within******** the framework of the NDIS******* .

Another instance involved participants who had daily support but refused it when their circumstances changed near end-of-life stage**, necessitating an appeal at tribunals where they faced questioning about consumables quotes as high as two thousand dollars each – all justifying disputes over basic continence care provided by health professionals during periods marked significantly reduced functionality caused directly by disabilities evident even before appeals began.“”\n6. Recommendations For Reform\n\nThe following are practical changes that would make substantial improvements both participant outcomes and sustainability:

1. Improve Consistency And Transparency:\nThere needs far greater consistency decisions made.

• Provide clearer guidance for all: Participants Providers IA planners!! \nNDIS needs real life guidance deciding what considered reasonable, necessary so participants providers know expect actually fair. \nEnsure planning better reflect clinical recommendations reduce variation currently seen between similar needs.* At moment* inconsistent outcomes creating confusion additional workload unnecessary appeals** 2 Reduce Administrative Burden The current level reporting justification unsustainable Streamline requirements duplication alone Accept standardised reports rather requesting repeated or slightly different information Avoid requiring rejustification supports significant change need Respect professionals present findings recommendation Clinicians spending time delivering services constantly rewriting same thing*** 3 Strengthen Early Intervention We stop cutting early only spend later Support intervention properly consistently Recognise reducing too often leads regression Factor in longterm cost savings funding decision

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

Submission 227

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.

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.

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 frontend providers and focusing on practical evidence-informed reform it possible improve outcomes while ensuring long-term sustainability Change needed acknowledged Ensuring these reforms informed front line personal experience will be critical achieving Bill’s intended outcome without compromising access Quality or System efficiency We great ideas they just need hear I many other service provider participant parents here hoping someone will hear us would openly welcome ANY consultation.