Submission 2307

Submission to the Senate Community Affairs Legislation Committee

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

Introduction

I am writing this submission as an NDIS participant with lived experience of the Scheme and as a Masters in Public Health student. This submission addresses provisions of the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 (the Bill), particularly those relating to eligibility, planning, sustainability, and the broader framing of disability support reform(5).

While reform of the NDIS is necessary, the current reform proposal relies on too many assumptions that have not yet been adequately tested, validated, operationalised or independently evaluated. The Bill prioritises expenditure restraint and administrative control without sufficiently regarding population-level health data, implementing a co-design method to change, or model economic impact onto other systems, organisations, businesses or bodies of government. The current reform proposals plan is incomplete without this further data, consideration and evidence.

Given the NDIA’s history of implementation difficulties(6), rapid and large-scale reform creates a substantial risk for operational issues to become structurally embedded before their consequences are properly understood. This submission calls for great caution, greater transparency and stronger safeguards than what’s currently proposed in the Bill.

Recommendation 1: Do a complete, and transparent, review of the factors contributing to cost growth

The NDIS emerged following findings by the Productivity Commission that disability services in Australia were fragmented, inequitable and underfunded(2). The Scheme was designed to provide people with disability greater choice, control and participation while aligning Australia with its obligations under the United Nations Convention on the Rights of Persons with Disabilities.

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The NDIS gained bipartisan support because it was fundamentally grounded in these principles(8). The original principles underpinning the Scheme have not been proven to be responsible for current expenditure pressures in the Bill. Rather, a constellation of implementation failures, operational struggles, governance weaknesses and structural market problems may have contributed to escalating costs, participant frustration and declining public confidence(6).

These factors warrant further investigation and include:

• rapid rollout before systems were fully mature(6)(8);
• inconsistent planning and review processes(1)(9)(11);
• lack of evidence-based decisions(8)(11)(13)
• lack of transparency and accountability(1)(9)(11);
• weak governance structure of the NDIA(1);
• unhealthy working culture within the NDIA(8);
• inadequate state-based disability infrastructure(1)(2)(7);
• provider market distortion and price gauging(8)(9)(14);
• biased and relentless media pressure(4);
• poor procedural oversight and due process(10)(11);
• lack of quality improvement processes and evaluation(8)(13);
• and poor administrative consistency(1)(8)(11)(13).

The Bill does not yet sufficiently address many of these structural causes. These reforms, while much needed, are incomplete without further data, consultation, co-design and input. Instead, many of the proposed solutions appear to assume implementation failures can be managed later through administrative discretion after legislation has already passed. Rapid rollout and inadequate administrative systems risk contributing to escalating costs and participant frustration.

It is more costly to do it wrong than to take longer to do it right.

Recommendation 2: Slow implementation to strengthen it

• and do it well

The proposed reforms are extensive, highly technical and exceed 200 pages in legislative and explanatory materia(5). Despite the scale of these reforms and their significant impact on disabled Australians, the consultation timeframe has been extremely limited to two weeks.

The Australian Government’s own Best Practice Consultation guidance recommends iterative consultation processes for reforms with significant social impact(15). The current process is inadequate and risks creating unintended implementation consequences that may take years to reverse.

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The history of the NNDIS already demonstrates how quickly operational problems become deeply embedded once systems are rolled out nationally(1)(6)(8)(13). There is little evidence presented that these reforms have been sufficiently piloted, modelled or stress-tested before implementation.

For this reason, I strongly recommend staged implementation, independent evaluation and mandatory post-implementation review periods. Large-scale reform affecting hundreds of thousands of disabled Australians should proceed carefully, transparently, with accurate data and with meaningful co-design. It should not be treated as a secondary exercise of administrative matters. While these reforms are long overdue, that is not an adequate justification to be reactive within policy reform.

Recommendation 3: Accurately describe and report on ‘integrity leakage’

The Bill is being introduced within a political and media environment heavily focused on fraud, rorts and sustainability concerns. While integrity measures are important, repeated emphasis on misuse risks creating a misleading perception that widespread abuse is the primary cause of NDIS cost growth when it is not(1).

Current public discourse frequently conflates deliberate fraud, administrative error, provider misconduct and broader integrity leakage into a single narrative of rorting. This creates stigma toward disabled people while obscuring structural drivers of expenditure growth, including provider market distortion, NDIA pricing decisions, governance failures and inadequate state disability systems.

I see a new headline everyday in the media making a mockery of the NDIS and of disabled people and I understand the frustration. This is an opportunity for the federal government to put its foot down. I agree that with the way things have played out, and the way the NDIS was designed/implemented, has demonstrated how far people are willing to push the envelope and take the piss out of it. I do believe this calls for reform, and that the government should set the terms. But I am not convinced these reforms achieve that.

The government should require annual public reporting that clearly separates deliberate criminal fraud from provider non-compliance, participant error, administrative mistakes and broader integrity leakage estimates. Without this distinction, public debate risks becoming distorted and policy responses risk becoming reactive rather than evidence-based.

Recommendation 4: Functional capacity assessments need further testing, validation, sensitivity and reliability

Submission 2307

The proposed reforms rely heavily on concepts of functional impairment and functional capacity. However, functional capacity and observed performance or capabilities are not equivalent concepts.

Many disabled people maintain employment, education or independent living through extraordinary personal effort and by masking the underlying severity and instability of their conditions. Many can be functionally capable with the right support. A participant may appear highly capable during periods of relative wellness while still experiencing profound impairment, episodic deterioration or periods of acute incapacity(11).

As much as these reforms wish for operational efficiency and to process disabled people through standardised measures, population-health data indicates many disabled people are comorbid, the social determinants of health directly impact health outcomes, and you cannot remove environment and personal circumstance from the person(16). If these reforms took into consideration the rates, prevalence and other health data available - it will become clear that these proposals are not cohesive and feasible as they stand - disease is interconnected and cannot be measured independently. Cutting supports by category will not impact the disabled community equally or equitably - some supports are more crucial for some disabilities more than others. Standardisation and disability are not compatible in the way it’s aspired to be in these reforms, therefore it must go back to the drawing board.

In research, tools must be validated before they are accepted. The same should apply here. I recommend that future assessment frameworks explicitly account for fluctuating conditions, pyschosocial disability, sustainability of functioning over time, cumulative exhaustion and episodic deterioration. There should be safeguards preventing sole reliance on standardised or automated assessment tools especially in the event of complex health.

A good example of complex health is myself. I am considered highly intelligent and highly presentable. Most people would not immediately identify me as disabled. After more than fifteen years of therapy (not paid by the NDIS), medication management and learning how to carefully structure my environment, I have figured out how to function relatively well under most everyday conditions. But I am fundamentally not stable. If my carefully curated ecosystem is disrupted, if I become significantly stressed, or if my supports are removed (which has happened), it can all collapse. I have experienced periods lasting six months where I was unable to leave my bed or function in any meaningful capacity. I am no good to anyone when I am like this and I truly try my best to avoid it.

I can perform well for short periods, but I cannot sustain it. Without the right support around me I cannot work consistently, yet when I am supported properly I contribute economically and socially like everyone else. My tax pays for my NDIS budget and more - but when I don’t have my support, I’m not working and my tax input is reduced. When I first became an NDIS participant, within the first year I was running a non-for-profit company with up to six staff members delivering crucial community based work. Once my access was revoked, that organisation was closed, those staff members let go, and that community that was receiving

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life-saving resources now abandoned - because my focus had to be exclusively reserved to my day-to-day survival. I became the community I was supposedly supporting.

I am concerned about the concept of functional impairment because in my case, I was subjected to this very threshold when my participation was revoked, and it was unnecessarily lengthy, hostile and difficult to navigate. After more than six months before the AAT, extensive historic clinical evidence, and substantial legal expenditure by the NDIA, I was ultimately recognised as functionally impaired. The amount spent attempting to remove my access was likely comparable to the value of my budget. It was a waste of public funds plain and square. Nobody won - the NDIA lost money, specialist hours that should be focused on treating were focused on report writing, I lost productivity and advancement in my studies and career and we have nothing to show for it. As someone who’s been forced to jumped through the hoops to demonstrate functional impairment I can confidently say the current tools are inadequate.

This is the type of structural failure I am alluding to throughout this submission. Systems that become overly focused on gatekeeping and cost containment can begin generating expensive, harmful and counterproductive administrative behaviour. They can also widen equity gaps rather than shrinking them(11).

Recommendation 5: Do not shuffle disability into

infrastructure that does not yet exist

A major concern with the Bill is the assumption that participants excluded from, or redirected away from, the NDIS will be adequately supported by mainstream or state-based systems.

Historically, state disability systems were fragmented and insufficient prior to the NDIS(2). Despite this, many alternative systems remain underdeveloped or inconsistent across jurisdictions(9). States and territories have had decades to improve disability infrastructure, yet substantial gaps remain. It is a bit farfetched to expect states and territories to suddenly now be properly fit-for-purpose if they haven’t since the inception of the NDIS. The Bill contains no enforceable mechanism requiring foundational supports or mainstream systems to be operational before participants are removed, redirected or denied access. This is especially true for children moving into the Thriving Kids program. This creates a substantial risk that disabled people will fall between systems.

Restricting access without simultaneously establishing robust community and state-based supports risks shifting costs into primary health networks, secondary and tertiary health systems including: hospitals, emergency departments, mental health systems, homelessness services; informal carers, and crisis systems. These systems are more costly to operate than upstream funding like the NDIS.

I understand these reforms intend to transfer those with psychosocial disabilities to more state-based systems. There is no functional legislative mandate or mechanism compelling

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states or territories to offer this service before participants are reprocessed - nor any guarantee that these services will be sufficiently piloted.

The Explanatory Memorandum does not adequately model these downstream impacts despite the availability of population-level health and economic data that could assist in doing so(5). I recommend this additional data be consulted and included with any reforms that depend on redirecting demand to alternative infrastructure and that there be guarantees that supports will not be removed without being replaced with existing systems (not hypothetical).

Recommendation 6: Address market distortion, pricing failures and strengthen provider/participant safeguards

Current reform discussions focus heavily on participant eligibility and expenditure growth while giving insufficient attention to structural market distortion within the disability support sector itself or occupational health and safety.

NDIS pricing frameworks and funding settings have significantly shaped provider behaviour, workforce allocation and market inflation. Participants did not independently create many of the inflated pricing conditions currently criticised within public debate. These conditions emerged within market settings designed, approved and regulated by the NDIA itself.

There are providers experiencing generational level wealth because of the NDIS and I don’t believe that was ever the intention - but none of this is addressed in the Explanatory Memorandum(5). To me, it reads at though there has been successful lobbying by some of the larger disability provider business who have a vested financial interest in consolidating and locking down the disability market. That way they have a monopoloy in the market that is only balance/contested by other large pre-existing businesses. If this is the case, and while I’m sure the argument here is that they are of better form/quality than unregistered providers - I implore the government to not that this reassurance on face value and to actually legislate quality guarantees if there’s plans to close the market.

Without addressing structural pricing and market incentives, reforms risk disproportionately targeting participant access while leaving broader expenditure drivers insufficiently examined. The government should undertake an independent review of NDIS pricing structures, provider market concentration and the contribution of NDIA pricing decisions to expenditure growth.

Safety is another issue not addressed in these reforms. Those taking the piss come at it from both sides. If we look at individual cases, there are numerous stories of support workers, plan managers and companies ripping off the disabled through the NDIS’. But the reverse of this can be true too. There are reports of disabled people sexually harassing or disrespecting support workers. This demonstrates an inherent disregard for another’s dignity and is a common human affliction found in any context. The disability sector needs safeguards, just like any other industry, to protect both providers and participants from these broader issues from seeping in.

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But these reforms don’t do that, despite claiming that extra regulatory powers are in the name of quality control.

All of this has been enabled by legislation that has been inadequate and may very well continue to be if it isn’t addressed head on(13). There is an opportunity, through these reforms, to address these quality safeguards by mandating provider and participant training. Given the NDIA’s legislative obligation, I was surprised and deeply concerned that the extra powers proposed for the NDIA are powers not granted to them upon the inception of the NDIS.

Recommendation 7: Strengthen safeguards around Ministerial powers and automation

The expansion of Ministerial rule-making and instrument powers within the Bill raises significant concerns regarding transparency, accountability and procedural fairness.

In particular, proposed section 34A would permit substantial alteration of support categories and funding arrangements through legislative instrument with limited parliamentary scrutiny and limited participant recourse(5).

The Bill should require publication of the evidence relied upon when support categories are changed, alongside disability impact statements and independent review mechanisms where changes materially affect participants.

I am also concerned by the increasing use of automation and algorithmic decision-making within the NDIS. Administrative efficiency is important, but Australia has already seen the consequences of poorly governed automated systems through Robodebt. The lesson from Robodebt is not that automation should never occur, but that automation without transparency, accountability and human oversight can produce catastrophic outcomes. I don’t see any deliberate attempt within these reforms to integrate these lessons.

Recommendation 8: Introduce stronger suicide-risk and continuity-of-care protections

The Bill does not adequately address participants at heightened risk of suicide, self-harm or severe psychosocial deterioration during reassessment, transition or support disruption.

For high-risk participants, abrupt funding changes or poorly coordinated transitions can create serious safeguarding risks. Continuity of care should not be treated as optional administrative best practice. It should be legislated.

Provider-to-provider handover obligations, hospital discharge coordination and continuity safeguards during disputes or reassessment should all be mandatory, particularly for higher-risk participants.

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Without these protections, many of the broader integrity and safeguarding reforms risk becoming performative rather than protective.

Recommendation 9: Measure the NDIS economic value - not just its expenditure

Debate surrounding the NDIS often focuses narrowly on expenditure without adequately considering broader social and economic returns. I see this reflected in the Explanatory Memorandum.

There is research demonstrating that the NDIS contributes substantial value to the Australian economy through workforce participation, employment generation and reduced reliance on crisis systems(1)(14). Existing evidence suggests every dollar invested in the NDIS generates broader economic return through increased participation and reduced long-term service demand(14).

This does not mean the Scheme should be exempt from reform. However, sustainability should not be assessed solely through short-term cost containment.

Poorly designed reductions may produce downstream costs elsewhere in the health and welfare system while simultaneously diminishing participation, stability and quality of life for disabled Australians. There’s not modelling offered in the Explanatory Memorandum despite the data being available. The economic impact these proposals will have on other systems of support and public health should be measured and considered before legislation is passed.

Recommendation 10: Commit funds to improving governance structure and workplace culture within the NDIA

This one is coming from personal experience. Nobody else but me can share my story so I might as well - otherwise what insight does Parliament have on how the NDIA treats participants? I cannot comment on why these cultural problems have arised but I can share my story to demonstrate they do exist and warrant further investigation as a general cultural climate review.

I want to preface this by saying outside of this one (2 year long) instance where the NDIA were committed to revoking my access to the Scheme, my interactions with the NDIA have been positive and helpful. This is not a criticism of the everyday public servant, but I am sharing my personal experience to illuminate how the governance structure and hierarchy at the NDIA requires improvement as my case relates to the most executive positions.

Submission 2307

When my access was revoked with one week’s notice and my 261 pages of further documentation detailing why I met the access criteria (as requested) was rejected within 45 minutes of being received, I had a sneaking suspicion that something was amiss.

But nobody wanted to explain why and what.

I submitted a Freedom of Information request and after a year of tug and war, I received (not all) some documentation that painted a concerning picture of the decision-making process involved on the back-end. Specifically, these concerns are broken below.

• The CEO of the NDIS (then Rebecca Falkingham) explicitly singled out and named me to be removed from the Scheme. There was no credible intelligence to justify this decision and no legal backing. In emails, you can read that she called upon her deputies to promptly remove me from the scheme with secondary regard to due process and procedural fairness.
• Most concerningly, none of her deputies pushed back against her request or quizzed her rationale. Nobody took a moment to critically reflect whether her orders were consistent with their statutory obligations as public servants and to clarify exactly what the CEO was requesting of them. These supposed executives either didn’t feel safe to challenge the CEO or they were happy to play an active role in her overexertion of power (that could be interpreted as misfeasance). Either way, this illustrates a culture problem.
• In further documentations, two delegates were combing through my invoices to find evidence that I was generating false claims. They felt they found the holy grail when they spotted that two of my invoices detailed how my support worker and I ‘had a coffee and a chat’. One replies ’where do I sign up for that service?’ Mocking my social needs that are impaired because of my disability (I was non-verbal those days) is not the type of people you want deciding what supports disabled people have access to.
• In email correspondances one of the delegates who was tasked with revoking my access asked her superior if she should read any of the evidence and letter I provided, pointing out that some of it warranted attention. She was told that it didn’t matter because this came ‘from the top’ and her concerns dismissed. This was the only pushback a member of the NDIA exercised during this task and they were promptly shut down and it was not looked into. This is a deeply entrenched workplace culture problem starting from the very top (CEO) and trickle all the way to the delegates.

I can only comment on events that have happened to me and I am only detailing these instances to illustrate the extent of disregard to statutory obligations, respect and dignity that executives at the NDIA are operating with.

For further context, I downplay the severity of the functional impairment caused by my disabilities because I understand it can be confronting for others and I don’t want to frighten the ones I care for. When my access to the Scheme was restored, it was done so with the addition of one further disability to prove my functional impairment. This was an entirely unnecessary exercise that cost the taxpayers.

Submission 2307

Summary of Recommendations

• Conduct a comprehensive and transparent review of all factors contributing to NDIS expenditure growth, including governance failures, market distortion, pricing structures, implementation challenges and administrative inefficiencies, before further narrowing participant access.
• Slow implementation of the proposed reforms and adopt a genuine co-design approach with disabled people, providers, researchers and other stakeholders. Require staged implementation, independent evaluation and post-implementation review before national rollout.
• Require annual public reporting that clearly distinguishes deliberate fraud, provider misconduct, participant error, administrative error and broader integrity leakage so that policy responses remain evidence-based and proportionate.
• Require functional capacity assessment tools to undergo further testing, validation and review before implementation. Assessment frameworks should explicitly account for fluctuating impairment, psychosocial disability, episodic deterioration, sustainability of functioning over time and cumulative exhaustion. Safeguards should prevent sole reliance on standardised or automated assessment tools.
• Delay participant transition, offboarding or eligibility tightening until foundational supports and alternative systems are independently verified as operational, adequately funded and capable of meeting demand. Participants should not lose support before replacement systems exist.
• Require publication of independent cross-system economic modelling assessing the impact of proposed reforms on healthcare, mental health, homelessness, crisis services, carers and other downstream systems before major eligibility restrictions occur.
• Undertake an independent review of NDIS pricing structures, provider market concentration and the contribution of NDIA pricing decisions to expenditure growth and market inflation.
• Review the NDIA’s governance structure, decision-making processes and organisational culture, including whether current systems support transparency, accountability, procedural fairness and evidence-based decision-making.
• Require mandatory disability impact statements, publication of supporting evidence and independent review safeguards for Ministerial rule-making powers, including those proposed under section 34A.
• Insert statutory safeguards preventing fully automated adverse eligibility decisions, automated budget reductions or other significant participant decisions without meaningful human review.
• Establish legislated continuity-of-care obligations, including provider-to-provider handover requirements, hospital discharge coordination and support continuity during reassessment, disputes and transition periods.
• Introduce mandatory clinical risk reviews and additional safeguards before substantial support reductions for participants at risk of suicide, self-harm or severe psychosocial deterioration.

Submission 2307

Strengthen provider and participant safeguards through mandatory training, clearer quality standards and stronger protections against abuse, exploitation, harassment and unsafe conduct within the disable support sector.

Conclusion

I want to reiterate how unacceptable it is that the timeframe given for this consultation is what it is. I have had 48 hours between my final assignments, alongside my disabilities, to write this submission and it’s not to the standard I could make it.

I am deeply grateful for the NDIS and know it has changed my life for the better (then for worse, but that’s a separate matter). I am proud of the NDIS and I want my government to feel proud of it too. I want the government to take pride in figuring out how to manage it.

The current Bill contains some potentially beneficial reforms, but these are incomplete at this stage and warrant further consultation, research, evaluation and co-design before being legislated. I understand change is necessary and can appreciate needing to have something legislated. I recommend that reforms with the strongest backing/evidence/rationale be preferenced if something must be legislated.

These reforms rely on significant assumptions regarding implementation capacity, alternative systems and participant impact that have not yet been sufficiently demonstrated - this must be done properly if it’s to be done at all.

Long-term sustainability cannot be achieved through cost containment alone. Sustainable disability policy requires coordinatation to analyse and synthesis all the information available and to ensure proposals are made with a continued commitment to the dignity, participation and rights of people with disability.

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References

1. Bennett S, Jessurun M, Orban H. Saving the NDIS: How to rebalance disability services to get better results. Grattan Institute; 2025. Accessed May 30, 2026. https://grattan.edu.au/wp-content/uploads/2025/06/Saving-the-NDIS-Grattan-Institute-Re port.pdf
2. Productivity Commission 2011, Disability Care and Support, Report no. 54, Canberra. Accessed May 30, 2026. https://assets.pc.gov.au/inquiries/completed/disability-support/report/disability-support-ov erview-booklet.pdf
3. Parliament of Australia. Budget Review, 2024-25: National Disability Insurance Scheme. Commonwealth of Australia; 2024. Accessed May 30, 2026. https://www.aph.gov.au/About_Parliament/Parliamentary_departments/Parliamentary_Li brary/Research/Budget_Review/2024-25/NDIS
4. Chinnappa M, Smith-Merry J, Chang K-YJ. The Cost of the National Disability Insurance Scheme: Australia’s Print-Media Discourse. Australian Journal of Social Issues. 2025. https://doi.org/10.1002/ajs4.70063
5. Parliament of Australia. National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Explanatory Memorandum; 2026. Accessed May 30, 2026. https://parlinfo.aph.gov.au/parlInfo/download/legislation/ems/r7487_ems_35e6531f-c440 -4faf-98d6-7c7ddd8bd539/upload_pdf/JC018272.pdf;fileType=application%2Fpdf#searc h=%22legislation/ems/r7487_ems_35e6531f-c440-4faf-98d6-7c7ddd8bd539%22
6. Hummell E, Foster M, Burns K, Rimmer SH. Policy shifts and drifts: From intention to implementation of Australia’s National Disability Insurance Scheme. Australian Journal of Public Administration. 2026;85(1):71–90. https://doi.org/10.1111/1467-8500.12689.
7. Cowden M, McCullagh C, Tran J. Australia Before the National Disability Insurance Scheme. 2021. Palgrave Macmillan, Singapore. https://doi.org/10.1007/978-981-16-2244-1_3
8. Duffy S, Brown M. Redesigning the NDIS: An international perspective on an Australian disability support system. Sheffield: Citizen Network Research; 2023. Available from: https://www.ndisreview.gov.au/sites/default/files/2023-11/DANA_Redesigning_the_NDIS _Dr_Simon_Duffy_and_Dr_Mark_Brown.pdf
9. Productivity Commission. National Disability Insurance Scheme (NDIS) Costs, Position Paper, Canberra. 2017. Accessed May 30, 2026. https://assets.pc.gov.au/inquiries/completed/ndis-costs/position/ndis-costs-position-overv iew.pdf 10.Parliament of Australia. National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill 2024. Community Affairs Legislation Committee, The Senate. 2024. Accessed May 30, 2026. https://lawyersalliance.com.au/common/Uploaded%20files/Submissions/2024/2024% 20Reports/2406%20Final%20Report%20Getting%20the%20NDIS%20Back%20on%20Tra ck%20No%201%20Bill%202024.pdf

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11. Shelby-James T, Duncan A, Rattray M, Reed R. National disability insurance scheme access: What evidence do you need to provide for psychosocial disability? Australas Psychiatry. 2023 Apr;31(2):174-177. doi: 10.1177/10398562231154117.

12. Parliament of Australia. No child left behind: Report into the Thriving Kids initiative. Standing Committee on Health, Aged Care and Disability, House of Representative. 2025. Accessed May 30, 2026. https://apo.org.au/sites/default/files/resource-files/2025-12/apo-nid333233.pdf

13. Carey G, Malbon E, Reeders D, Kavanagh A, Llewellyn G. Redressing or entrenching social and health inequities through policy implementation? Examining personalised budgets through the Australian National Disability Insurance Scheme. Int J Equity Health. 2017 Nov 6;16(1):192. doi: 10.1186/s12939-017-0682-z

14. D’Rosario M, Lloyd-Cape M. FALSE ECONOMY: The economic benefits of the National Disability Insurance Scheme and the consequences of government cost-cutting. Per Capita; 2021. Accessed May 30, 2026. https://percapita.org.au/wp-content/uploads/2021/11/NDS_031121_per-capita-report.pdf

15. Department of he Prime Minister and Cabinet. Best Practice Consultation. Office of Best Practice Regulation. 2020. Accessed May 30, 2026. https://oia.pmc.gov.au/sites/default/files/2021-09/best-practice-consult.pdf

16. Australian Institute of Health and Welfare. Social determinants of health. 2024. Accessed May 20, 2026. aihw.gov.au/reports/australias-health/social-determinants-of-health

Acknowledgement of AI ChatGPT was used to help structure this submission and clarify my writing.