Safeguarding Sustainability While Protecting Participants; A Frontline Clinical Perspective on the Proposed National Disability Insurance Scheme Reforms

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

Safeguarding Sustainability While Protecting Participants: A Frontline Clinical Perspective on the Proposed National Disability Insurance Scheme Reforms

Submitted by: Urzi Supports Author: Dino Urzi Clinical Psychologist and Director Urzi Supports Registered NDIS Provider

About the Author

Dino Urzi is a Clinical Psychologist and Director of Urzi Supports, a registered National Disability Insurance Scheme (NDIS) provider delivering psychological services, psychosocial recovery coaching, support coordination, clinical supervision and disability support across Queensland.

Through both his clinical practice and leadership of a multidisciplinary organisation, Mr Urzi works closely with participants living with psychosocial disability, autism spectrum disorder, intellectual disability, acquired brain injury, neurological conditions and other complex disabilities. His work regularly involves collaboration with participants, families, carers, psychiatrists, general practitioners, allied health professionals, hospitals, housing providers, the justice system and the National Disability Insurance Agency.

The observations contained within this submission are informed by frontline clinical practice and the practical realities of delivering NDIS supports every day. They reflect recurring themes observed across a broad range of participants and are offered respectfully to assist the Senate in understanding how the proposed reforms may operate in practice.

Introduction

Every day, Australians living with disability place their trust in the National Disability Insurance Scheme to provide the supports that allow them to live safely, independently and with dignity. As clinicians and registered providers working alongside those participants every day, we recognise both the extraordinary achievements of the NDIS and the importance of ensuring its long-term sustainability. It is in that spirit that we make this submission.

Urzi Supports is a registered NDIS provider delivering evidence-based psychological services, psychosocial recovery coaching, support coordination, clinical supervision and disability support throughout Queensland. Our organisation supports people living with psychosocial disability, autism spectrum disorder, intellectual disability, acquired brain injury, neurological conditions and other complex disabilities that require coordinated, multidisciplinary and person-centred care.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

As both a Clinical Psychologist and Director of a registered NDIS provider, I have the privilege of working alongside participants, families, carers, support workers, clinicians, allied health professionals and government agencies every day. My perspective is informed not only by clinical practice but also by the practical realities of implementing the NDIS within communities.

Urzi Supports believes the NDIS is one of Australia’s most significant social reforms. It has transformed countless lives by providing opportunities for greater independence, social participation, employment, education and improved wellbeing. We recognise that, like any major public program, the Scheme must continue to evolve to ensure its long-term sustainability.

While this submission focuses primarily on participants living with psychosocial disability, many of the observations are equally applicable to participants living with autism spectrum disorder, acquired brain injury, intellectual disability and other disabilities characterised by fluctuating or complex functional needs.

Purpose of this Submission

Urzi Supports acknowledges the Australian Government’s commitment to ensuring the long- term sustainability of the National Disability Insurance Scheme.

We support reforms that improve consistency, strengthen governance, reduce fraud and ensure public resources are directed towards participants who genuinely require support.

Our purpose is not to oppose reform.

Rather, this submission identifies areas where additional safeguards, greater legislative clarity or modest amendments may reduce the likelihood of unintended consequences for participants living with complex and fluctuating disabilities.

The recommendations contained within this submission seek to strengthen the proposed reforms while preserving the principles of participant choice and control, evidence-informed practice, individualised decision-making and person-centred care that underpin the NDIS.

  1. Functional Capacity Assessments and Fluctuating Disability

Relevant proposed reform: The proposed introduction of a statutory definition of functional capacity and increased reliance on functional capacity assessments when determining eligibility and funded supports.

We understand the Government’s objective of creating greater consistency and transparency in decision-making. A more clearly defined assessment framework has the potential to improve equity across the Scheme.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

However, we are concerned that greater reliance on functional capacity assessments may unintentionally disadvantage participants living with psychosocial disability and other conditions characterised by fluctuating functional impairment.

Unlike many physical disabilities, psychosocial disability rarely presents as a fixed or static condition. A participant may appear articulate, organised and capable during an assessment while simultaneously requiring substantial support to maintain housing, attend appointments, manage medication, regulate emotions, sustain relationships or remain safe within the community.

As clinicians, we regularly observe participants who demonstrate impressive insight during appointments yet deteriorate significantly when faced with everyday stressors outside the clinical environment.

A single assessment conducted on a relatively stable day cannot adequately capture this complexity.

Similarly, individuals living with autism spectrum disorder frequently expend considerable emotional and cognitive effort masking their difficulties during structured interactions. Functional assessments that rely heavily upon observation within a limited timeframe risk underestimating the true level of daily impairment.

We respectfully encourage the Senate to ensure that legislation explicitly recognises fluctuating disability and provides decision-makers with sufficient flexibility to consider longitudinal clinical evidence, treating practitioner reports and documented patterns of functioning over extended periods rather than relying predominantly upon single-point assessments.

Doing so would better reflect contemporary clinical understanding while maintaining fairness and consistency.

  1. Narrowing the Definition of Reasonable and Necessary Supports

Relevant proposed reform: The proposed amendments refining the definition of “reasonable and necessary” supports together with expanded Ministerial powers to prescribe categories of supports that may or may not be funded.

We recognise the importance of providing greater clarity regarding the boundaries of NDIS funding.

Clear legislative guidance assists participants, providers and decision-makers alike.

However, disability does not exist in neatly defined categories.

Many supports achieve outcomes that extend beyond the immediate activity being funded. Assistance with community participation, transport or routine building may appear relatively simple in isolation, yet collectively these supports often prevent psychiatric deterioration,

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

reduce social isolation, maintain employment, improve medication adherence and reduce demand upon acute health services.

For participants living with psychosocial disability, the value of a support frequently lies not only in what it achieves today but in the crisis it prevents tomorrow. An overly prescriptive interpretation of reasonable and necessary supports risks reducing planners’ capacity to consider the unique circumstances of each participant.

The NDIS was intentionally designed around individualisation rather than standardisation.

Maintaining appropriate flexibility within legislative definitions will better enable planners to achieve outcomes that remain both clinically effective and economically responsible.

  1. Permanence Requirements and Access to the Scheme

Relevant proposed reform: The proposed requirement that decision-makers consider whether all appropriate and available treatment has been undertaken before disability is considered permanent.

We understand the rationale behind ensuring that appropriate treatment opportunities have been explored before long-term disability supports are provided.

However, this proposal raises significant concerns for participants living with severe and persistent mental illness.

Modern mental health treatment frequently aims to improve quality of life, reduce symptom severity and maximise functioning rather than cure illness entirely.

Many participants continue engaging in psychiatric care, psychological intervention and medication management throughout their lives while nevertheless experiencing enduring and substantial functional impairment.

There is a significant difference between a condition being treatable and a disability no longer being permanent.

Requiring evidence that all available treatment has been exhausted may unintentionally delay access to essential supports for participants who have already demonstrated years of persistent disability despite sustained engagement with evidence-based treatment.

Clinical judgement must remain central to these decisions.

The legislation should continue to recognise that permanence can coexist with ongoing treatment.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

  1. Greater Reliance on Mainstream Services

Relevant proposed reform: The proposed clarification of the interface between the NDIS and mainstream service systems, including greater consideration of whether participant needs should instead be met through health, housing, education or community services.

Urzi Supports strongly supports improved collaboration between government systems.

The interface between disability, health and social services has historically been fragmented and could benefit from greater clarity.

However, our concern is not with the intention of this reform but with the practical reality of its implementation.

Across Queensland, public mental health services remain under significant pressure. Community mental health programs frequently operate with extensive waiting periods. Affordable housing remains scarce. Allied health services continue to experience workforce shortages, particularly within regional communities.

Redirecting participants towards systems that are already operating beyond capacity does not remove their need for support.

Instead, it risks transferring costs from the NDIS into hospitals, emergency departments, homelessness services, policing, corrective services and other government systems.

In our experience, the participant does not become less disabled simply because responsibility for funding changes.

Rather, their access to timely intervention is reduced.

We respectfully recommend that any legislative changes strengthening the interface between the NDIS and mainstream systems be accompanied by corresponding investment in those systems to ensure participants are not left without appropriate supports.

  1. Administrative Burden and Its Impact on Participant Care

Relevant proposed reform: Proposed governance, compliance and administrative reforms designed to strengthen oversight, improve consistency and ensure Scheme sustainability.

Urzi Supports, supports appropriate regulation and robust governance.

Public confidence in the NDIS depends upon accountability, transparency and responsible stewardship of public resources.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

However, there is an important distinction between effective accountability and excessive administrative burden.

Over recent years, providers have experienced increasing documentation requirements, reporting obligations, compliance activities and administrative processes.

While each individual requirement may appear reasonable, their cumulative impact is substantial.

Every additional hour spent completing documentation represents an hour unavailable for participant care.

For psychologists, support coordinators, recovery coaches and frontline support workers, administrative growth inevitably reduces the time available for therapeutic intervention, capacity building and meaningful participant engagement.

Smaller providers may be particularly affected.

Unlike larger organisations, smaller regional providers often operate with limited administrative resources. Excessive compliance costs may reduce their financial viability, ultimately limiting participant choice and reducing access to services within regional and rural communities.

We encourage the Senate to ensure that future compliance requirements remain proportionate to the risks they seek to address and are evaluated according to whether they demonstrably improve participant safety and Scheme integrity without unnecessarily reducing frontline service delivery.

The Importance of Measuring Success Beyond Cost

The sustainability of the NDIS is rightly a central objective of the proposed reforms.

However, sustainability should not be measured solely by reductions in Scheme expenditure.

The true measure of success should be whether reforms improve participant outcomes while reducing overall demand across the broader health, housing, justice and social service systems.

Every psychiatric admission prevented, every tenancy maintained, every participant who remains employed, every family able to continue caring safely for a loved one and every individual who avoids involvement with emergency services represents both a positive human outcome and a sound economic investment.

When evaluating the success of these reforms, we respectfully encourage the Senate to adopt a whole-of-government perspective rather than assessing outcomes exclusively through the financial performance of the NDIS itself.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

Investment in timely, preventative supports frequently generates significant savings elsewhere across government while improving quality of life for Australians living with disability.

  1. Participant Anxiety, Certainty and Confidence in the Scheme

Relevant proposed reform: The proposed changes to planning processes, plan reassessments, review mechanisms and the introduction of greater structure around planning and funding decisions.

One of the less visible consequences of legislative reform is the impact that uncertainty has upon participants themselves.

While policy discussions often focus on funding, sustainability and administration, the individuals receiving supports frequently experience reform through a very different lens. Many of the participants we support have expressed genuine fear that the changes may result in reduced supports, disruption to trusted relationships or a reassessment of their disability despite no meaningful improvement in their condition.

For participants living with trauma, anxiety disorders, autism spectrum disorder and psychosocial disability, prolonged uncertainty can itself become a significant contributor to declining mental health. The anticipation of losing support often produces increased anxiety, emotional dysregulation and reduced engagement in recovery activities long before any formal decision has been made.

We have observed participants delaying employment opportunities, withdrawing from community participation and experiencing worsening mental health simply because they are uncertain about what the future of their supports may look like.

We encourage the Senate to ensure that implementation of the proposed reforms is accompanied by clear, accessible and consistent communication. Participants should understand not only what is changing, but why it is changing, how decisions will be made and what avenues remain available if circumstances change.

Confidence in the Scheme is itself an important contributor to participant wellbeing.

  1. Continuity of Therapeutic Relationships

Relevant proposed reform: Proposed planning and funding reforms that may influence participants’ ability to maintain established therapeutic supports over time.

One of the strongest predictors of successful outcomes in psychological treatment, recovery- oriented practice and disability support is the quality and continuity of therapeutic relationships.

Trust cannot be legislated.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

It develops gradually through consistency, reliability and shared experience.

Many participants supported by Urzi Supports have spent months or years developing sufficient trust to disclose trauma, accept support, engage with treatment and participate meaningfully within their communities.

Changes that unintentionally disrupt these relationships may have consequences extending far beyond a simple change of provider.

Participants living with complex trauma, personality disorders, psychosocial disability and autism frequently rely upon consistency to maintain emotional regulation and engagement. Repeated disruption can undo significant therapeutic progress and require months of rebuilding before meaningful intervention can resume.

We respectfully suggest that future planning decisions explicitly recognise continuity of care as an important factor when determining participant supports. While efficiency and consistency remain important objectives, they should be balanced against the well-established evidence supporting stable therapeutic relationships.

  1. Fraud Prevention and Scheme Integrity

Relevant proposed reform: Expanded compliance, investigative and enforcement powers intended to reduce fraud, misuse of Scheme funds and inappropriate claiming.

Urzi Supports strongly supports measures that protect the integrity of the NDIS.

Fraud, exploitation and deliberate misuse of public funds undermine confidence in the Scheme and divert resources away from participants who genuinely require support.

Effective regulation benefits participants, providers and taxpayers alike.

However, we encourage the Senate to ensure that compliance frameworks remain proportionate, evidence-based and targeted towards deliberate wrongdoing rather than creating unnecessary complexity for participants and legitimate providers.

The overwhelming majority of participants seek only to live safe, meaningful and independent lives. Likewise, the overwhelming majority of registered providers work diligently to meet increasingly rigorous regulatory requirements while delivering high-quality supports.

Legislation should distinguish clearly between intentional misconduct and inadvertent administrative error.

Compliance systems that become overly punitive or unnecessarily complex may discourage innovation, reduce provider participation and ultimately limit participant choice.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

Strong regulation and accessible service delivery should be complementary objectives rather than competing priorities.

  1. Recognising the Complexity of Psychosocial Disability

Relevant proposed reform: Increased reliance upon functional capacity as a central determinant of eligibility and support needs.

Throughout this submission we have highlighted concerns relating specifically to psychosocial disability because this cohort remains particularly vulnerable to unintended consequences arising from legislative reform.

Psychosocial disability cannot be understood solely through observable functional performance.

Symptoms fluctuate according to stress, trauma exposure, medication changes, physical health, social circumstances, housing stability, interpersonal relationships and countless other environmental factors.

Executive functioning, motivation, emotional regulation, concentration, decision-making and insight may vary dramatically over relatively short periods.

Participants who appear highly capable in structured environments may struggle profoundly when managing the cumulative demands of daily life independently.

This complexity is well recognised throughout contemporary psychiatric and psychological practice.

Legislation that relies predominantly upon static functional assessment risks overlooking these realities.

We respectfully encourage the Senate to ensure that specialist clinical evidence remains central to decision-making and that legislative guidance explicitly acknowledges the fluctuating nature of psychosocial disability.

Doing so will improve both fairness and clinical accuracy while supporting more effective allocation of Scheme resources.

Observations from Frontline Clinical Practice

The following observations are drawn from our experience supporting participants across a broad range of disabilities, with a particular focus on psychosocial disability, autism spectrum disorder, acquired brain injury, intellectual disability and complex mental health presentations. While every participant’s circumstances are unique, these observations reflect consistent themes encountered through everyday clinical practice.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

  1. Participants often present at their best during formal assessments.

Many individuals devote enormous effort to appearing organised, articulate and capable during appointments. For some, this is the result of masking behaviours developed over many years. For others, it reflects anxiety, fear of being judged or a desire to demonstrate progress.

Unfortunately, these brief snapshots can create an inaccurate impression of a participant’s day-to-day functioning.

The greatest challenges often emerge after the assessment has concluded, when participants return home and attempt to manage the ordinary demands of daily life without support.

  1. Recovery is rarely a straight line.

Recovery should not be mistaken for the absence of disability.

Many participants experience meaningful improvements while continuing to require significant supports to maintain those gains.

Periods of progress are frequently interrupted by illness, trauma, grief, changes in medication, financial stress, housing instability or family breakdown.

These setbacks should not be interpreted as failure. They are an expected part of many disabilities and should be anticipated within planning processes.

  1. The participants who need the most support are often the least able to advocate for themselves.

Many individuals living with severe psychosocial disability, intellectual disability or acquired brain injury struggle to navigate complex administrative systems.

Some miss deadlines. Some do not understand correspondence. Others become overwhelmed and disengage entirely.

A reduction in advocacy or support should never be interpreted as a reduction in need.

  1. Prevention is significantly less expensive than crisis response.

Every hospital admission avoided, every tenancy maintained, every police attendance prevented and every participant who remains engaged in employment or education represents both a human success and a financial saving.

The value of many NDIS supports lies in preventing deterioration before it occurs.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

When preventative supports are withdrawn, the costs rarely disappear. They are transferred to hospitals, emergency departments, police, housing services, carers and other government systems.

  1. Therapeutic relationships are themselves a clinical intervention.

Participants often tell us that the most valuable aspect of their support is not simply the task being completed, but the trusted relationship that has developed over time.

Consistency promotes trust. Trust promotes engagement. Engagement promotes recovery.

Disrupting these relationships may appear administratively efficient but can have significant clinical consequences.

  1. Flexibility improves outcomes.

Disability does not follow administrative schedules. Participants experience good days and difficult days. Some weeks require intensive support. Other weeks require very little.

The ability to respond flexibly to changing circumstances often prevents relatively minor challenges from developing into major crises.

  1. Families remain the hidden support system.

Behind many successful participants is a family member quietly coordinating appointments, providing transport, managing medications, responding to crises and advocating with multiple agencies.

When formal supports are reduced, these responsibilities are frequently transferred to ageing parents, partners, siblings and carers who may already be experiencing significant emotional, physical and financial strain.

The impact of legislative reform therefore extends well beyond the individual participant.

  1. Workforce stability matters.

Participants benefit from consistency not only in funding, but also in the people providing their supports.

Administrative complexity, increasing compliance requirements and uncertainty within the sector can contribute to workforce turnover.

When experienced clinicians, support workers and coordinators leave the sector, participants lose valuable relationships and organisational knowledge that cannot easily be replaced.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

  1. Success cannot always be measured by independence.

One of the greatest strengths of the NDIS has been recognising that success looks different for different people.

For one participant, success may be gaining employment. For another, it may be avoiding hospital admission. For someone else, success may simply be leaving their home, maintaining personal hygiene, rebuilding a relationship with family or feeling safe enough to participate in their community.

These outcomes are equally meaningful and deserve equal recognition.

  1. Sustainability and participant outcomes are not competing objectives.

Throughout our work, we have consistently observed that the participants who receive timely, coordinated and appropriate supports are often those who place the least demand on emergency departments, inpatient mental health services, homelessness services, policing and crisis response systems.

Supporting participants well is not only clinically appropriate; it is economically responsible.

The long-term sustainability of the NDIS should therefore be viewed not simply through the lens of reducing expenditure within the Scheme itself, but through its capacity to reduce expenditure across the broader health, housing, justice and social service systems while enabling Australians living with disability to participate more fully in community life.

Final Reflection

As clinicians and registered providers, we recognise that legislation alone cannot capture the complexity of disability. Every participant brings a unique combination of strengths, vulnerabilities, aspirations and challenges.

The greatest strength of the NDIS has always been its capacity to recognise that individuality.

As Parliament considers the future of the Scheme, we respectfully encourage decision-makers to preserve the flexibility, clinical judgement and person-centred principles that have enabled so many Australians living with disability to build safer, healthier and more independent lives. A sustainable NDIS is not achieved by simply reducing expenditure.

It is achieved by investing wisely, intervening early, preventing crises and ensuring that every decision keeps the participant at the centre of the Scheme.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

Recommendations

Urzi Supports respectfully recommends that the Senate consider the following amendments and safeguards before implementing the proposed reforms.

  1. Ensure legislative definitions of functional capacity explicitly recognise fluctuating disabilities, including psychosocial disability.
  2. Preserve sufficient flexibility within the definition of reasonable and necessary supports to enable genuinely individualised decision-making.
  3. Retain clinical discretion when determining permanence and avoid reliance solely upon treatment history as evidence of ongoing disability.
  4. Ensure mainstream service systems receive adequate investment before responsibility for participant supports is shifted away from the NDIS.
  5. Maintain continuity of therapeutic relationships as an explicit consideration during planning and review decisions.
  6. Design compliance and governance frameworks that are proportionate to risk and minimise unnecessary administrative burden on providers.
  7. Continue meaningful consultation with participants, carers, clinicians, registered providers and disability advocacy organisations throughout implementation.
  8. Establish an independent evaluation framework that publicly reports on participant outcomes, hospital presentations, housing stability, employment participation, carer wellbeing and quality of life following implementation of the reforms.
  9. Measure the success of the reforms using whole-of-government outcomes rather than focusing solely on reductions in NDIS expenditure.
  10. Commit to reviewing the operation of the legislation within two years of commencement to identify and address any unintended consequences.
  11. Ensure the implementation of the reforms is undertaken in partnership with participants, carers, clinicians and registered providers, recognising that those delivering and receiving supports are uniquely placed to identify unintended consequences early.

Composite Case Studies Illustrating the Potential Impact of the Proposed Reforms

The following case studies are composite examples based on common presentations encountered through our clinical practice. They do not describe any individual participant and have been prepared to protect participant confidentiality while illustrating recurring themes observed across multiple participants.

Case Study One – Fluctuating Functional Capacity

“Sarah” is a woman in her thirties living with complex post-traumatic stress disorder, recurrent major depressive disorder and severe anxiety.

During formal assessments, Sarah presents as articulate, insightful and capable of discussing her treatment and daily life. On the surface, she appears to have relatively few support needs.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

However, her day-to-day functioning tells a very different story. Without regular psychosocial support, Sarah stops attending medical appointments, neglects personal care, becomes socially isolated and struggles to leave her home. During periods of deterioration she has experienced repeated psychiatric admissions and episodes of homelessness.

A functional capacity assessment conducted during a period of relative stability would likely underestimate the level of disability she experiences over time.

Her recovery has depended upon consistent support that recognises fluctuating disability rather than isolated observations made during assessment.

Case Study Two – The Value of Early Intervention

“Michael” lives with schizophrenia and has been engaged with mental health services for many years.

Historically, reductions in community support have resulted in medication non-adherence, deterioration in mental state, repeated emergency department presentations and lengthy psychiatric admissions.

Following the introduction of consistent psychosocial recovery coaching and coordinated support, Michael has maintained stable housing, remained engaged with treatment, significantly reduced hospital presentations and developed meaningful community participation.

The annual cost of these preventative supports is substantially lower than the cost associated with repeated inpatient admissions.

This case demonstrates that early intervention is not an additional expense. It is an investment that reduces long-term costs across multiple government systems while improving participant outcomes.

Case Study Three – Continuity of Therapeutic Relationships

“Emma” has autism spectrum disorder, complex trauma and longstanding difficulties trusting services due to previous experiences of abuse.

It took more than eighteen months before Emma consistently engaged with psychological treatment and accepted support from her disability support team.

The therapeutic relationship became the foundation upon which every subsequent improvement was built.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

When changes in funding temporarily disrupted this support, Emma disengaged from treatment, withdrew from community participation and experienced a marked deterioration in her mental health.

Rebuilding trust required many months.

While administrative changes may appear relatively minor, their impact upon participants who depend upon stable therapeutic relationships can be profound.

Case Study Four – The Limits of Mainstream Services

“David” experiences severe psychosocial disability and was encouraged to access mainstream mental health services for aspects of his ongoing support.

Although clinically appropriate in principle, the local public mental health service was unable to provide regular psychosocial intervention because of workforce shortages and high demand.

As a result, David’s support reduced significantly despite no reduction in disability.

Within months he experienced housing instability, increased police contact following behavioural escalation and an emergency psychiatric admission.

The issue was not that mainstream services were inappropriate.

Rather, they lacked sufficient capacity to provide the intensity and continuity of support required.

This example highlights the importance of ensuring mainstream systems are adequately resourced before responsibility for participant supports is transferred away from the NDIS.

Case Study Five – The Cost of Administrative Burden

A registered provider supporting participants across multiple regional communities observed that increasing administrative requirements required clinicians, recovery coaches and support coordinators to devote substantially more time to documentation and compliance activities.

While each individual requirement was reasonable in isolation, the cumulative effect resulted in fewer hours available for participant contact, delayed reviews and reduced opportunities for proactive intervention.

Participants did not experience improved outcomes because of increased administration.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

Instead, the reduced availability of clinicians limited opportunities to prevent deterioration before crises developed.

This illustrates the importance of balancing accountability with the practical realities of frontline service delivery.

These composite examples demonstrate that disability is rarely experienced in neat legislative categories. Functional capacity fluctuates, recovery is non-linear, and participant outcomes often depend upon consistency, continuity and timely intervention. Legislative reform should preserve sufficient flexibility to recognise these realities while continuing to strengthen the long-term sustainability and integrity of the National Disability Insurance Scheme.

Collectively, these examples demonstrate that the value of the NDIS is often measured not by the services it funds, but by the crises it prevents.

What this submission ultimately asks of the Senate

This submission does not ask the Senate to reject reform. It asks the Senate to ensure that reform remains faithful to the purpose for which the National Disability Insurance Scheme was established.

The recommendations contained within this submission seek to strengthen the proposed legislation by preserving flexibility, recognising the complexity of disability, supporting clinical judgement and protecting participants from unintended harm while continuing to improve the Scheme’s long-term sustainability.

The most successful reforms will be those that achieve both objectives simultaneously.

Closing Remarks

Urzi Supports recognises that reform of the National Disability Insurance Scheme is both necessary and inevitable.

We support measures that strengthen the Scheme’s long-term sustainability, improve consistency of decision-making, enhance accountability and ensure public resources are directed towards participants who require them.

Our submission should not be interpreted as opposition to reform.

Rather, it reflects the perspective of a registered provider and Clinical Psychologist working directly alongside individuals whose lives are profoundly influenced by the operation of the NDIS every day.

We believe the proposed reforms are motivated by a genuine desire to secure the future of the Scheme. Our concern is that some reforms, if implemented without appropriate safeguards,

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2450

may unintentionally disadvantage participants living with complex, lifelong and fluctuating disabilities.

The long-term success of the NDIS should be measured not only by financial sustainability, but also by its ability to improve lives, preserve dignity, promote independence and strengthen community participation.

A financially sustainable Scheme that no longer achieves these objectives cannot truly be considered successful.

Conversely, a Scheme that invests wisely in early intervention, continuity of care and evidence-informed supports has the potential to reduce long-term expenditure across health, housing, justice and emergency services while delivering better outcomes for Australians living with disability.

We respectfully encourage the Senate to consider whether modest refinements to the proposed legislation could preserve its objectives while reducing the risk of unintended consequences for those the Scheme was ultimately created to support.

On behalf of Urzi Supports, our staff, and most importantly the participants and families we have the privilege of supporting, we thank the Committee for considering this submission. Many participants living with complex disability are unable to effectively articulate the impact these reforms may have upon their lives. For this reason, clinicians, carers and frontline providers have an important responsibility to ensure their experiences are represented during legislative reform.

The future of the NDIS will ultimately be judged not by how much it costs, but by how effectively it enables Australians living with disability to live safe, connected, independent and meaningful lives.

Yours faithfully,

Dino Urzi

Clinical Psychologist Director Urzi Supports

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