National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
Submission to the Senate Community Affairs Committee National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Who I am
I am a disabled person with the direct lived experience of both relying on the NDIS and being severely harmed by the way it is already being administered. I have already had to challenge NDIS decisions through review processes, including the ART, multiple times and I am now preparing to do so again. Like many in the disability community, I am tired of being treated as a political football whenever it is convenient. I have had to fight repeatedly for basic supports and to challenge decisions that did not reflect my documented needs. My experience is that when the system gets things wrong, the burden falls on the disabled person to survive the consequences and then fight to correct them.
I have already experienced the NDIS cutting supports in ways that are consistent with the direction of the proposed legislation, not once but twice. I do not believe I am alone in this experience. In my view, these cuts are already happening in practice.
My disabilities and support needs are significant, ongoing, and well documented, yet my experience has been that clear evidence is often ignored, misunderstood, or treated as less important than administrative convenience. The result has been repeated stress, unsafe gaps in support, and constant pressure to prove needs that are already obvious to the professionals supporting me. I have lost significant amounts of functional capacity in ways that could have been preventable if planners had read my reports the first time through. My current plan is underfunded, and the planner has made serious errors of judgement, including misunderstanding what is actually available in my region’s public system and misunderstanding the goals of my care.
I do not have family who can safely or appropriately step in to meet my care needs. My housemate has been pressured to take on more of my care by NDIS staff, even though they are not supposed to be responsible for my care. I rely on funded supports for basic safety, including food, daily living, supervision, communication, advocacy, and access to appointments. When those supports are reduced, delayed, or wrongly refused, the consequences for me are immediate, serious and potentially life threatening.
I am making this submission because I truly believe the bill will worsen existing failures within the NDIS itself, in accountability, communication, review rights, and individualised decision-making. I am angry, hurt, and frightened by what I have already experienced, and I believe these changes will increase the risk of isolation, neglect, serious harm, and avoidable deaths for disabled people, including me.
Let me make this clear: I do not support this Bill. In my view, it has not been properly thought through, and its impact risks pushing disability care further back toward older patterns of neglect,
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
segregation, carer crisis, and deadly outcomes that disabled people in Australia know far too well. Any Bill of this scale should be developed through proper consultation with the disability community at large, not only with SIL providers, major charities, or large organisations. It must have the lives of disabled people at its centre, and it must include real accountability for the NDIA. Disabled people in Australia know what happens when governments normalise under-support, carer burnout, segregation, and bureaucratic indifference: people are neglected, isolated, abused, and sometimes die.
In my view, this bill does not fix the failures I have already experienced in the NDIS; it entrenches them. It gives the Agency and the Minister broader powers at the same time that participants are facing weak accountability, ignored evidence, communication barriers, and exhausting review processes. For those reasons, I ask the Committee not to pass the Bill in its current form and to recommend substantial amendments or better yet, veto this bill entirely.
Issue 1: The timing of this bill
One of my strongest concerns is the speed at which this Bill has been pushed through consultation. This is a large and complex Bill that would change access to the NDIS, planning, reassessment, review rights, and the way supports are defined and funded, yet the disability community was given only a very short time to understand it and respond. The short timeframe has also made it difficult for legal and advocacy organisations to analyse the Bill in full. For example, the Justice and Equity Centre noted the Bill’s length and complexity and said the consultation period was so short that its explainer could not cover every change or include recommendations on which parts should be amended or opposed.
That is not a minor procedural problem. Many disabled people need extra time, support, accessible formats, help from advocates, allied health, support workers, or trusted others just to read, process, and respond to legislation of this scale. A rushed process does not affect everyone equally; it disadvantages the very people most affected by the Bill, especially people with communication barriers, cognitive load issues, fatigue, trauma, high support needs, and limited informal support.
To many disabled people, this process feels less like consultation and more like being asked to rubber-stamp changes that were already decided.
The Office of Impact Analysis says best practice consultation should be genuine, proportionate, and appropriate to the scale and impact of the proposal. Yet even the government’s own NDIS reform impact analysis was assessed only as “Adequate,” and the public consultation period for this Bill was extremely short given its breadth and consequences.
In my view, that process has not allowed for genuine consultation with the disability community. It has created the impression that disabled people are being asked to respond to major legal changes under conditions that make meaningful participation much harder.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
Recommendation: The Senate should recommend that the Bill not proceed in its current form unless the consultation period is extended and all key rules, tools, and operational details are released for proper public scrutiny in accessible formats; and, more importantly, only when the foundational systems that they are proposing moving people to, actually exist.
Issue 2: How this bill was produced My second major concern is the way this Bill has been developed. It has been presented as though it reflects genuine co-design with the disability community. In practice, that is not how it feels or is in reality. From where I stand, the process has felt selective, top-down, and weighted toward institutions, providers, and administrative priorities rather than toward the lived experience of the participants who will have to survive the consequences.
The government says people with disability have a say through advisory groups, co-design working groups, Disability Representative Organisations, and public consultation processes. But genuine co- design is more than asking for tokenistic feedback after the direction of reform has already been set. Co-design means involving disabled people early, sharing real decision-making power, and being transparent about what feedback has been accepted, rejected, or ignored, and why. It also means listening to people across different disability groups and support needs, and allowing them to explain what works, what does not, and why certain changes may cause harm.
My concern is that the current process has not met that standard. Too many disabled people, especially those with complex needs, high support needs, communication barriers, trauma, regional disadvantage, or negative experience of the NDIA, do not feel that these reforms were shaped with us, but like previous legislation is rather done to us. The result is a Bill that reads less like something built from lived reality and more like something built from system priorities such as cost control, standardisation, and administrative convenience.
Disability representative organisations have already said that people with disability and their organisations must be front and centre in the design of NDIS reform, and that co-design of rules, guidance, and systems must be genuine rather than retrospective. That concern matters even more here because so much of the detail appears to be left to later rules, tools, and implementation processes rather than being fully visible on the face of the Bill. And lets face the truth, rules that are not in the legislation can’t be challenged easily and thus take further away from our enshrined right to review.
In my view, this process has created a serious trust problem. Disabled people are being asked to accept sweeping changes while being told to trust that the details will be worked out later, even
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
though many of us have already experienced what happens when NDIA systems exercise wide discretion without enough accountability.
Being invited to comment after the architecture of reform has already been built is not genuine co-design; it is managed consultation.
Collectively, disabled people are too often expected to be grateful simply for being given any seat at the table at all, even when the direction of reform appears to have already been decided. At the same time, public discussion about the NDIS has increasingly been framed through the language of fraud, unsustainability, and lost “social licence,” rather than through the lived reality of disabled people who rely on the Scheme to stay safe and alive. The government has repeatedly spoken about the NDIS losing its “social licence,” but that language has consequences. It contributes to a climate in which disabled people and advocates are treated as the problem, rather than as people trying to protect the supports that keep us alive.
I believe that if the public were more exposed to the real experiences of disabled people navigating the NDIS, many would be far more concerned about the direction of these reforms. Disabled advocates are already reporting hostility and abuse simply for defending their rights and supports. Parliament has the power to look past public panic and political framing, and instead focus on the real impact this Bill will have on disabled people, workers, families, and the systems expected to absorb the fallout.
Recommendation: The Senate should recommend that the Bill not proceed unless the government commits to genuine co-design of all rules, guidance, assessment tools, and implementation systems with disabled people and their representative organisations from the earliest stage, with public transparency about what feedback is accepted and why.
Issue 3: Dangerous Overreach of Powers My third major concern is that this Bill gives the Minister and the NDIA broader powers over what disabled people can receive, while existing accountability mechanisms are already too weak. In a system where participants are already struggling with ignored evidence, poor communication, long delays, inconsistent explanations, and exhausting review processes, giving the government more power to narrow, standardise, or reduce supports is dangerous.
The Bill is presented as a way to make the NDIS sustainable and clarify what can be funded, but the practical effect appears to be much broader than simple clarification. Analyses of the Bill have raised concern that the new framework would allow funding to be reduced across categories of supports, including at reassessment or renewal, and would make it easier for cohorts of participants to be affected by ministerial settings or caps rather than individual need. That is especially alarming in a Scheme that is supposed to respond to individual disability-related needs, not broad budget settings.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
Most participants are not living luxurious lives. We are trying to secure the basics: food, showering, supervision, communication, transport, therapy, safety, and the support needed to survive day to day. Powers that allow governments or agencies to reduce support categories from above may look administrative on paper, but in real life they mean people going without meals, care, transport, communication support, allied health, community access, and safety.
A clear example of how harmful this can be is augmentative and alternative communication, or AAC. There are people, including me, who need AAC desperately. Yet the way these changes are being framed means devices like iPads can be treated as excluded or pushed into a narrower “replacement support” pathway, even though iPads run many of the AAC applications people rely on to communicate. Our voices are not a luxury and they are not an optional extra; they are a critical support.
The alternative often suggested is a dedicated communication device from a disability-specific provider, but those devices can cost several thousand dollars more while offering less flexibility than mainstream technology. In practice, this means participants can be pushed away from cheaper and more functional communication options and toward more expensive, more restrictive ones simply because of how the support is classified. That is not efficiency, and it is not participant- centred decision-making.
Many disabled people, especially those of us living on the disability pension, are already highly skilled at making limited resources stretch. We know when a more expensive item is genuinely necessary, when a cheaper item will do the job, and where mainstream purchasing can save money without sacrificing safety or function. We often know how to reduce costs better than the system does, including by buying ordinary items such as continence products more cheaply through mainstream retailers, or by using an unlocked iPad for AAC rather than a more expensive, more restrictive device sold through a disability-specific provider. We also know which allied health supports we need not only to maintain the bare minimum, but sometimes to make modest gains that prevent further decline.
A clear example in my own life is psychology support that was removed after being treated as “mental health only,” when in reality it was helping me manage the consequences of my disabilities. That support was teaching me how to identify and express emotions safely, how to set boundaries, how to say no to people trying to pressure or harm me, and how to maintain the relationships that keep me alive, including with my housemate. Because my communication is fragmented and I often do not understand other people or the social world around me, those supports were essential to helping me interface with the world more safely. Removing them does not remove the need; it transfers the consequences onto me, the people around me, and crisis- based systems that do not have the capacity or expertise to respond safely. In my view, that kind of decision increases the risk of harm, self-harm, exploitation, hospitalisation, and profound isolation.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
I have already experienced very serious harm in circumstances where I did not have adequate support to recognise grooming, protect myself, or get help in time. That is why I reject the idea that these are optional or secondary supports. For some of us, they are part of what keeps us alive.
I have already experienced supports being cut in ways that feel consistent with the direction of this Bill. I have experienced decisions being made that did not reflect my documented needs, my region, the actual availability of services, or the risks created when a support is reduced. That history is one reason I do not trust wider ministerial or administrative power to be exercised safely.
My concern is not theoretical. When disabled people lose supports, the burden does not disappear; it is pushed onto families, housemates, emergency departments, overstretched public systems, and sometimes onto nobody at all. For people with high and complex needs, that can mean neglect, crisis, hospitalisation, abuse, and avoidable deaths. A support system cannot be called individualised if a Minister can effectively reduce supports for whole groups of people from above. The more power this Bill gives to Ministers or the Agency to define, cap, reduce, or standardise supports for broad groups of people, the less protection there is for participants whose lives do not fit neat categories.
The more power this Bill gives to Ministers or the Agency to define, cap, reduce, or standardise supports for broad groups of people, the less protection there is for participants whose lives do not fit neat categories. That is the opposite of what a disability support system should do. Parliament needs to understand that these decisions are not abstract budget settings. They shape whether disabled people are safe, fed, heard, believed, protected, and able to survive. Senators considering this Bill have a responsibility to prevent reforms that widen power while deepening harm.
Recommendation: The Senate should recommend that any provision allowing the Minister or the NDIA to reduce, cap, standardise, or narrow categories of supports be removed or substantially amended, and that no participant’s supports be reduced by category, cohort, or reassessment setting unless there is a fully individualised decision with clear reasons, transparent evidence, and full review rights.
Issue 4: Automation and the Removal of the Right to Review My fourth major concern is the move toward greater automation in NDIS decision-making and administration. In a system that already struggles with ignored evidence, poor communication, lost documents, inconsistent explanations, and truly exhausting review processes, introducing automation risks scaling those failures rather than fixing them.
My concern is not with technology in the abstract. It is with the use of automation in a system where the underlying decisions are already too often flawed, poorly explained, and difficult to challenge. If an automated process is trained on past decisions, administrative shortcuts, incomplete records, or patterns of misunderstanding, then it will not create fairness; it will reproduce existing unfairness faster and at greater scale.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
We do not need to guess what can happen when governments rely on automated systems in high- stakes human decisions. Robodebt showed the catastrophic consequences of using automation to generate harmful outcomes at scale, while placing the burden on ordinary people to prove the system wrong. People were harmed, people were pushed into crisis, and public trust was deeply damaged. Disabled people should not be asked to accept a similar logic in the NDIS.
The people most likely to be hit hardest by automated decision-making are the same people already most at risk in inaccessible systems: people with communication barriers, cognitive disability, trauma, limited support, fluctuating capacity, and difficulty navigating hostile or confusing bureaucratic processes. When those people are forced to challenge a harmful decision, the burden is not theoretical. It can affect safety, food, communication, housing, health, and survival.
I am also deeply concerned about the way disability-related needs are already misread as something else. In my experience, support needs connected to communication, emotional regulation, social understanding, and safe participation in the world are too easily dismissed as “just mental health” or treated as though they are personal failings rather than consequences of disability. An automated system will not solve that problem if it is trained on decisions, assumptions, and records that already reflect those misunderstandings. It risks reproducing them faster, with less transparency and less opportunity for meaningful correction.
Robodebt should have taught Parliament that automation is not neutral when it is built on bad assumptions, poor records, and power imbalance.
I am also an archivist by training. That means I have professional knowledge of how records should be received, stored, managed, and retrieved, and it makes what I have experienced with the NDIA even more alarming. Based on both my training and my lived experience, I believe the way the NDIA receives, stores, misfiles, and loses documentation is inconsistent (at best) with the recordkeeping standards government agencies are supposed to meet. When reports go missing, old reports are used instead of current ones, or key documents cannot be produced accurately in review processes, that is not a minor administrative failure. It undermines procedural fairness, makes meaningful review harder, and creates real risk when decisions about essential supports are made on incomplete or inaccurate records.
If the Agency cannot reliably manage records in a human decision-making system, it should not be trusted to automate decisions that depend on accurate records, accurate reasoning, and accurate communication.
Disabled people are not affected equally by the kind of change proposed in this bill. People with communication barriers, cognitive disability, trauma, fluctuating capacity, limited support, or difficulty processing hostile or confusing systems are far more likely to be harmed when decisions become less transparent and less human. A system cannot be called accessible if participants are expected to challenge life-affecting decisions they cannot properly understand, decode, or respond to in time.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
In my own experience, I have had planners lose reports, rely on old reports, fail to read reports properly, misunderstand the medical language in reports, and give inconsistent accounts of what material was used to make decisions. I have also experienced situations where the documents provided in review processes were incomplete, where my communication needs were not respected, and where the burden fell on me to identify and correct the Agency’s errors. If those same failures are embedded into automated decision-making or automated administrative pathways, the harm will not disappear; it will become faster, more opaque, and harder to reverse.
This matters because decisions about plans, reassessments, suspension, contact, funding, and support categories are not minor administrative matters. They affect whether disabled people like me eat, shower, communicate, attend appointments, maintain safety, stay housed, and remain connected to the people and systems that keep them alive. A person should not lose essential supports because an automated process treated incomplete data, a missed contact, or a misunderstood record as sufficient to justify harm.
One of my concerns is that these changes may make it easier for the Agency to avoid the kind of genuine, holistic consideration that participants have had to fight for through review processes in the federal courts. Too often, participants are already forced to challenge plans that appear to have been made without properly reading or weighing the very reports the NDIA asks for. When that happens, the burden falls on the participant alone (not supported, because that is not allowed) to seek internal review and then external review, even though those processes are exhausting, slow, confusing, and often inaccessible.
The problem is made worse when review rights are narrowed in practice, delayed, or made so confusing and exhausting that only the most resourced participants can persist. A right to review is not meaningful if the participant cannot see the reasons, cannot access the material relied upon, cannot communicate safely with the Agency, or cannot survive the wait for correction. For many disabled people, the issue is not only whether review technically exists, but whether it is accessible, timely, and capable of preventing serious harm, or in cases like mine, or, in cases like mine, ending harm that is already occurring.
Automation should never be used to make or substantially shape adverse decisions about access, funding, reassessment, suspension, or plan changes. At the very least, no automated system should be used where a participant may lose support, face delay, or be exposed to greater risk without a genuinely informed human decision-maker reviewing the evidence, giving clear reasons, and preserving full rights of challenge. And by genuinely informed, I also mean that human decision-maker must also be properly trained to read and weigh medical and allied health evidence, not just apply administrative or fiscal rules.
A system that already gets basic human decision-making wrong should not be given permission to make those same mistakes faster by machine.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
Recommendation: The Senate should recommend that the Bill prohibit automated adverse decision-making in the NDIS, including any automated process that materially influences access, planning, reassessment, suspension, funding, or support classification. The Senate should also require that participants receive clear reasons, access to the material relied upon, accessible communication, proper recordkeeping, prompt internal review, and full external review rights for any decision that affects their supports
Issue 5: Suspension of a plan because of un-contactability My fifth major concern is the proposal to suspend a participant’s plan because they are considered “uncontactable.” In theory, that may sound administrative. In practice, for many disabled people, it is dangerous. It creates a real risk that people will lose essential supports not because they refused to engage, but because the NDIA failed to communicate with them in a way they could actually access, process, or respond to.
Disabled people do not all communicate in the same way. Some people cannot reliably process phone calls, some cannot safely respond under pressure, some need written communication, some need support people involved, and some may appear to have made contact when in reality they did not understand what was being asked or what was being decided. A contact attempt is not meaningful if it ignores the participant’s documented communication needs and preferences.
In this context, the real question is not whether the NDIA attempted contact. The real question is whether the NDIA communicated in a way that respected disability, allowed understanding, and made genuine participation possible. Anything less risks turning disability-related communication barriers into a reason to punish the participant.
In my own case, my speech pathologist has explicitly stated in reports that the NDIA should not be trying to communicate with me by phone. She has explained that my processing capacity in phone calls is extremely limited, that I can dissociate under stress, and that I may only remember fragments of what happened afterwards. She has also made clear that I cannot reliably consent to legally significant decisions communicated verbally in a hostile or pressured environment. My communication preference has consistently been text or written communication, yet that preference has repeatedly been ignored.
This problem is made even worse by the fact that I need AAC, and that need has already been partially denied or ignored. The NDIA cannot reasonably say that I am “uncontactable” while at the same time failing to properly recognise and support the communication methods I need in order to engage. When a person’s communication supports are denied, minimised, or misclassified, the risk is not just misunderstanding. The risk is that the participant is set up to fail and then penalised for that failure.
Under a system like the one proposed, the NDIA could call me a few times, ignore my communication needs, and then treat me as “uncontactable,” even though the failure would be theirs, not mine. That could lead to the suspension of my plan and the loss of supports I rely on for
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
food, safety, communication, daily living, and access to appointments. That is not a neutral administrative outcome. It is a direct pathway to harm.
This issue goes beyond my own case. Deaf participants, autistic participants, people with intellectual disability, people with psychosocial disability, people with brain injury, people with trauma histories, and people with fluctuating capacity are all at risk if “contact” is defined in a narrow or superficial way. Picking up the phone is not the same as understanding, consenting, or being able to protect your own interests. Confused speech, distress, silence, or fragmented responses should not be treated as evidence that the NDIA has meaningfully engaged with a participant.
A system that already ignores communication preferences cannot safely be trusted with a power like this. Before any suspension power is even contemplated, the law should require the NDIA to follow documented communication needs, use accessible methods, involve nominated supports where appropriate, and show genuine efforts to communicate in a way the participant can actually understand and respond to.
Recommendation: The Senate should recommend that no participant’s plan be suspended for alleged un-contactability unless the NDIA has first complied with the participant’s documented communication preferences and support needs, used accessible communication methods, involved nominated supports where appropriate, and provided a clear, reviewable decision with reasons.
Issue 6: Delays, Environmental Considerations and Registrations My sixth major concern is the way this Bill would allow delays and more rigid decision-making in a system that already fails to respond safely when support needs change. In my own case, I spent more than six months waiting for an emergency review and new plan to add a new disability and increase critical supports, during a period when I was only funded to be fed three meals a week. That is not a minor delay. It is a situation of real risk.
Delays of this kind are dangerous because disabled people do not stop needing food, care, supervision, transport, therapy, or communication support while the NDIA takes months to act. By the time a response comes, a person may already have lost function, become more isolated, been pushed into crisis, or been forced to rely on unsafe or inappropriate informal care. A system that takes months to respond to urgent change is not operating safely.
The Bill also appears to narrow the ability to seek an unscheduled plan review by limiting that pathway to unforeseen circumstances. In practice, that is deeply unsafe. Many of the risks disabled people face are not “unforeseen” in the ordinary sense; they are foreseeable consequences of underfunding, delay, ignored evidence, and unmet support needs.
Carer burnout is foreseeable, especially when supports are not funded properly. Severe choking episodes are foreseeable when a person has documented dysphagia and inadequate support. Meltdowns that place workers or participants at risk are foreseeable if decision-makers understand
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
the participant’s disability and warning signs. The progression of serious illness is foreseeable when a person has a known diagnosis.
A system should not be allowed to ignore those risks simply because they were predictable. If anything, foreseeability should create a stronger obligation to act, not a weaker one. Removing or narrowing access to unscheduled plan reviews in those circumstances will not reduce harm; it will entrench it.
Environmental reality also matters, and this Bill does not appear to take that seriously enough. I live on the outskirts of a regional city, where public transport is negligible, taxis are limited, and it is not realistic or safe to assume that services are readily available in the same way they might be in a major metropolitan area. If travel is not funded, support workers will not come to me, and appointments in larger centres become effectively inaccessible because I do not have the transport funding in my core budget to attend.
The NDIA has already made unsafe assumptions about my circumstances by treating the fact that I maintain a driver’s licence, and sometimes have access to a car, as though I am independently able to go out into the community. That is not true. I maintain a licence because of the realities of regional living and emergencies, and I only drive safely because I severely limit how much I drive, as it causes exhaustion and pain for hours, days, or longer. Using that fact to deny transport support ignores the difference between having a licence and actually being able to access the community safely and reliably. It also relies on the false assumption that the owner of the vehicle, who has it with him most of the time, would simply give me access to it whenever I wanted, regardless of whether he has work or other responsibilities.
The same problem arises when the NDIA ignores the role of environment in personal care and dignity. In practice, a failure to properly fund supports can mean that care is pushed onto whoever happens to live with the participant, regardless of whether that is appropriate, safe, consensual, or sustainable. In my case, that means assumptions that my Male housemate should absorb intimate and essential parts of my care when they are not responsible for my care and are already experiencing burnout. That is not choice and control. It is cost-shifting dressed up as planning.
Regional and remote participants are especially exposed to this kind of harm. Workforce scarcity, long travel distances, limited public systems, and reduced provider choice mean that a plan that looks workable on paper may be completely unworkable in real life. If the law lets the NDIA ignore environment, stretch response times, or make abstract assumptions about informal support and service availability, then participants like me will be left with plans that cannot actually keep us safe.
Registration also cannot be looked at in the abstract, because in regional areas the real question is not just whether a provider is formally registered, but whether safe, skilled, reliable care is actually available at all. In a regional city, the workforce is already scarce, choice is limited, and participants are often left choosing between large providers that drain funding while sending whoever is
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
available, or independents who may be the only workers with the right skills, continuity, and understanding.
In my experience, large providers often promise quality and safety but then send workers who do not know me, do not understand my needs, and are not properly briefed before entering my home. For many disabled people, especially those with complex needs, trauma, communication barriers, or safety concerns, being expected to open the door to unfamiliar workers is not a minor inconvenience. It can be unsafe, destabilising, and completely incompatible with the kind of care we actually need.
By contrast, my independent support workers have been the people who consistently show up, understand my needs, and provide the highest standard of care. They are also the people who have most consistently identified provider fraud and poor practice. Their work is not cheaper because they are cutting corners; it is better because it is informed, consistent, and accountable. If the government wants to improve service quality, it should focus on minimum qualifications, minimum care standards, and clear safety expectations across the market rather than making independent work harder or less viable
A plan is not genuinely workable if it assumes services exist when they do not, assumes workers will travel when that time/distance is not funded, or assumes a participant can simply switch to a registered provider when the available providers are unsafe, poor quality, or not suitable for that person’s disability-related needs. In regional, rural, and remote areas especially, registration settings must not be used in ways that reduce the small amount of real choice, continuity, and safety that participants still have.
It is also very important that participants remain able to choose their own plan managers and support coordinators. When those functions are limited, absorbed, or controlled in ways that reduce independence, participants lose choice, control, impartiality, and often the practical understanding that keeps them safe.
For someone like me, it is critically important that any support coordinator understands how Autism affects communication, processing, and regulation, and how Ehlers-Danlos Syndrome affects my body and physical safety. When they do not understand those disabilities properly, they can suggest supports or routines that are not merely unhelpful, but actively unsafe or allow planners to do so. In my own case, a planner suggested that I should be able to do a home exercise program with my support worker during the same time that worker was supposed to cook for me, supervise me eating, help me shower, help with laundry, and manage the rest of my basic daily supports, despite being told that unsupervised land-based exercise is not safe for me without allied health oversight.
That kind of decision shows why these services matter. When individualised support coordination, trusted plan management, and genuinely informed guidance are removed or narrowed, participants do not simply lose administration. We lose safety, advocacy, continuity, and the
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
practical understanding needed to prevent harm. In my view, reforms that limit choice in these areas, or remove support coordination entirely, risk leaving disabled people more exposed to neglect, unsafe decisions, and preventable harm.
Recommendation: The Senate should recommend that the NDIA remain under a clear duty to respond promptly to changed circumstances, that unscheduled reviews remain available where delay would create risk, and that all planning and reassessment decisions be required to take account of the participant’s real environment, including regional location, transport access, workforce availability, informal support limits, safety, and dignity.
Recommendation: The Senate should also ensure that any registration or market reforms do not reduce access to skilled independent workers or make regional plans unworkable in practice.
Recommendation: The Senate should recommend that the NDIA have a legislated clear duty of care that dictates maximum response times based on assessed risk level by allied health and medical staff, what substantially remedied or finished actually means.
Issue 7: Reassessments My seventh major concern is the way reassessments operate in practice, and the way this Bill appears to make them even more dangerous. Reassessment is often presented as a neutral administrative process, but in reality it can be one of the main points at which disabled people lose supports, are forced to re-prove obvious needs, and are pushed into systems that do not have the capacity or expertise to meet those needs.
The government’s own timeline states that tighter criteria for unscheduled plan reassessments will begin shortly after Royal Assent, and that from 2028 existing participants will be reassessed over three years under new access settings linked to a standardised functional-capacity approach. That makes reassessment a central risk point in this Bill, not a side issue.
In my own experience, reassessment has not been a fair or genuinely evidence-based process. I have been through multiple reassessments and my consistent experience has been one of having to fight planners who did not properly understand my disabilities, did not properly read the reports in front of them, or substituted their own assumptions for allied health evidence. I have had to repeatedly challenge decisions that did not reflect my actual needs, my risks, or the reality of the services available where I live. I have also experienced hostility, disbelief, and decisions made without real understanding. I have been yelled at by planners, told that I do not understand my own disabilities as well as they do, and told that things my body does are not physically possible, despite those issues being entirely consistent with a connective tissue disorder. I have then been told that I must transfer to the public system, even though that system does not have the capacity or expertise to meet my needs, and clearly does not have that capacity in my region.
A particularly serious example is psychology support that was removed after being treated as “mental health only,” even though it was helping me manage the consequences of my disabilities
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
and function more safely in the world. That support was helping me understand emotions, communicate more safely, set boundaries, maintain relationships, and reduce the risk of harm. Removing it does not remove the need; it simply pushes the consequences onto me, the people around me, and systems that do not have the expertise to respond appropriately. It creates a real risk of physical and psychological harm.
This matters because reassessment is not just about budgets on paper. It is often the mechanism through which disability-related needs are reclassified, minimised, or shifted elsewhere. In my case, I have been told that supports connected to autism, communication, regulation, and functioning belong in the public mental health system, even though that system does not have the capacity or disability-specific expertise to provide what I need, especially in my region. Being pushed into an under-resourced or inappropriate system is not support. It is abandonment by another name.
Reassessments are even more dangerous when they are carried out through standardised frameworks, narrow functional measures, or decision-makers who do not understand how multiple disabilities interact. My needs do not fit neatly into one box, and many disabled people are in the same position. A system that reassesses people through rigid categories while ignoring cumulative impact, lived reality, and treating-professional evidence is a system that will predictably get people’s lives wrong.
The practical burden of reassessment also falls heavily on participants. We are expected to gather reports, explain ourselves over and over, survive gaps in support, and challenge bad decisions through processes that are exhausting, slow, and inaccessible. For many disabled people, repeated reassessment is not a safeguard. It is a mechanism of instability, attrition, and harm.
For many disabled people, reassessment does not feel like review; it feels like being repeatedly forced back into a fight for survival.
I am also deeply concerned by the way this Bill narrows eligibility, funded supports and functional capacity to only impairments that meet the access threshold, rather than the full reality of a person’s disability. The government’s own fact sheet says supports will only be funded where the need arises directly from an impairment for which the participant met NDIS access, and independent analysis has warned that the new framework will not consider overlapping conditions holistically. For people like me, whose needs arise from multiple interacting disabilities, that creates a real risk that the system will effectively treat one impairment as the only one that matters and ignore the way my conditions compound each other in daily life.
I am equally concerned by the tightening of the definition of permanence through the phrase “materially improve, reverse, or alleviate.” A disability can be lifelong and still be partly alleviated by equipment, therapy, medication, pacing, or other interventions. Someone with cerebral palsy may function better with a wheelchair, but that does not mean their disability has stopped being permanent. The risk is that the better a person manages their disability, or the more effectively
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
they use supports and assistive technology, the easier it becomes for the system to argue that they no longer qualify or that parts of their need now sit outside the Scheme.
A reassessment system that tries to split those needs into neat boxes will get people like me wrong. It risks treating some needs as outside of scope, secondary, or someone else’s responsibility, even when the reality is that those needs cannot be separated safely in practice. For participants with complex and interacting disabilities, that kind of narrowing is not clarification. It is a pathway to under-support and harm.
While the Bill may not say in simple words “we will only support one disability,” the practical effect of tying supports more tightly to eligible impairments and standardised functional-capacity assessment is that people with multiple interacting disabilities risk being treated as though only one part of their disability matters. That is not how disability works in my life or anyone elses.
Recommendation: The Senate should recommend that reassessment powers be tightly limited, that unscheduled reassessments remain available wherever needs or risks change, and that no participant be reassessed under new frameworks in a way that reduces supports unless the decision is based on properly considered treating-professional evidence, holistic assessment of multiple interacting disabilities and medical conditions, and full review rights. The legislation should also make clear that participants are not to be assessed or funded as though only one eligible impairment matters where their functional capacity and support needs arise from multiple interacting disabilities.
Issue 8: Removal of Individualised Plans My eighth major concern is that this Bill moves the NDIS further away from individualised support and closer to standardised planning, narrower categories, and decisions that treat disabled people as administrative types rather than whole people. I am a person, not a number, not a category, and not an abstract “participant cohort.” My disabilities do not fit neatly into separate boxes, and they should not have to in order for me to receive support that is safe and effective.
The government’s own materials say funded supports must arise directly from an impairment for which the participant met access, and the new framework planning approach is linked to more standardised functional-capacity assessment. Independent analysis has warned that the Bill will not assess overlapping conditions holistically. Taken together, that creates a real risk that individualised plans will be replaced in practice by narrower, more standardised packages that fail to reflect the real complexity of people’s lives.
In my own case, a “typical” or standardised support approach would get my life badly wrong. It would ignore my dysphagia, my mobility needs, my need for a wheelchair, my ongoing therapy needs, my communication difficulties, my autism-related support needs, my ARFID, and the fact that I require a level of daily support far beyond what a generic profile could safely capture. A standardised plan might look tidy on paper, but in reality it would leave me under-supported, unsafe, and at risk of rapid decline.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
I have Level 2 Autism, Avoidant Restrictive Food Intake Disorder, Complex Post-Traumatic Stress Disorder, and Hypermobile Ehlers-Danlos Syndrome recognised by the NDIS. I also live with other conditions, including Postural Orthostatic Tachycardia Syndrome and Mast Cell Activation Syndrome, that interact heavily with my recognised disabilities. Each condition compounds the severity of the others. It is often impossible to cleanly separate what comes from what, and trying to force that separation is not only artificial but dangerous. A TSP would not consider that I need weekly OT, Psychology, Hydrotherapy, Exercise Physiology; and fortnightly Physiotherapy, Speech Pathology access, or monthly Podiatry, Dietitian access; in addition to being assessed as needing 12 hours a day of supports including standing overnight supports. It would not account for my hallucinations when I am alone. It would not account for the fact that without many of these supports, I would be in SDA or SiL in 24/7 care, which would cost far far more than just funding the therapies that I need
This is why the move toward treating supports as though they must be tied to one eligible impairment, or one main disability, is so alarming in practice. Even if the Bill does not use those exact words, the practical effect of narrowing support to eligible impairments and standardised functional measures is that people with multiple interacting disabilities may be treated as though only one part of their disability matters. That is not how disability works in my life. It is not how support needs arise, and it is not how harm happens when support is removed.
A genuinely individualised plan must consider the whole person, the interaction between conditions, the participant’s real environment, the cumulative burden of disability, and the evidence of the professionals who know them. A system that replaces that with standardised planning tools, narrower impairment rules, or “typical” plans will not create fairness. It will simply make it easier to under-support people whose lives are more complex than the framework allows.
How would anyone expect me to choose between my disabilities? My Ehlers-Danlos Syndrome makes my life physically painful and unstable. My Autism makes the social world confusing, overwhelming, and at times dangerous. They do not take turns. They interact all day, every day.
Recommendation: The Senate should recommend that the legislation preserve genuinely individualised planning, prohibit the use of standardised support profiles or typical support plans as a substitute for individual assessment, and require all planning and reassessment decisions to consider the cumulative impact of multiple interacting disabilities, medical conditions, environment, and treating-professional evidence.
Issue 9: Functional capacity assessments / ICAN / unvalidated assessment tools. My ninth major concern is the proposed move toward standardised functional-capacity assessments, including tools such as the ICAN, being used to determine access and support needs. In theory, that may sound efficient. In practice, it risks replacing deep, individualised understanding with shallow measurements that do not capture how complex disability actually works in real life.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
I am deeply concerned that tools like the ICAN are being relied on in ways they were never designed for. My understanding is that the ICAN was developed around intellectual disability and focuses heavily on what a person can do in a narrow or surface-level sense. That makes it a deeply unsafe fit for people like me, whose disabilities involve pain, exhaustion, instability, sensory overload, fluctuating function, compensation strategies, and the cumulative effect of multiple interacting conditions.
A tool like this may record that I can technically perform a task, while completely missing what it costs me to do it, how long I can sustain it, whether I can do it safely, whether I can repeat it, and what happens to my body afterwards. Technically, I can bend over. That does not mean I can do it reliably, repeatedly, or without harm. Technically, I can walk. That does not capture the severe pain, instability, exhaustion, and prolonged recovery that follow. And to explain in excruciating detail about what that means: it results in the muscles in my legs being grabbed painfully hard, electrocuted, and being shredded by a thousand shards of glass with every single step that I take. It feels like my muscles are literally being torn off my legs with every movement. That pain shoots up my back, my balance starts to disappear, my knees start wobbling and buckling. And it doesn’t go away.. it continues for up to 45 minutes. Stopping doesn’t stop the pain. Forcing myself to continue walking just hurts me for weeks. And that doesn’t even include feeling the pop, pop, pop of my hips sliding in and out of place when I walk without crutches.
The same problem applies across daily life. An assessor may see a person complete a task once and record “capacity,” while missing the sensory, physical, cognitive, or emotional consequences that make the task unsustainable in the real world. That kind of assessment does not measure disability accurately. It rewards masking, compensation, adrenaline, and self-harm through overexertion.
I am also deeply concerned about who will be conducting these assessments and how much training they will actually have. My treating professionals have spent years building trust with me, learning how my body works, understanding how I compensate, and noticing risks that I myself did not have words for or was too embarrassed to disclose. Even with that level of expertise and trust, important issues continue to emerge over time. It is not credible to suggest that a relatively briefly trained assessor using a standardised tool will be able to understand my functional capacity better than the professionals who actually know me.
That concern is especially serious where the NDIA may then rely primarily on the assessor’s report rather than the evidence of treating clinicians. My occupational therapist, psychologist, speech pathologist, physiotherapist, and other allied health professionals know how my disabilities interact and what support I need to remain safe. A one-off assessment cannot replace that body of knowledge. If anything, giving the NDIA another reason to disregard treating evidence will make bad decisions more likely, not less.
Functional-capacity assessment should never become a shortcut for denying complexity. It should never be used as a blunt instrument to reduce access, cut supports, or override the evidence of the professionals who know the participant best. For people with complex, interacting, fluctuating,
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
or poorly understood conditions, a narrow tool can easily become a machine for producing underestimation and harm.
Recommendation: The Senate should recommend that no standardised functional-capacity assessment tool, including the ICAN, be used as a determinative or overriding basis for access, planning, or reassessment decisions. Any such assessment should be strictly supplementary, transparently validated for the disability groups to which it is applied, and incapable of displacing detailed evidence from treating medical and allied health professionals.
Issue 10: “All Appropriate Treatments” and “Materially Alleviate.” My tenth major concern is the tightening of access and permanence through the phrases “all appropriate treatment” and “materially improve, reverse, or alleviate.” On paper, these phrases may sound reasonable. In practice, they create a dangerous and deeply uncertain standard that can be used to deny people support even where their disability is lifelong, serious, and plainly disabling.
The Bill says access will only be granted where all appropriate treatment to remedy or alleviate an impairment has been undertaken, and where no other treatment is likely to materially improve the impact of the impairment. That creates at least three major problems. First, it gives the NDIA enormous power to decide what counts as “appropriate treatment” without the mandate to tell the person what they should have tried (This is the same concept as when someone applies for something in other government departments. They are told what they are missing so that they can go get it. The NDIA on the other hand, sends a person on a blind scavenger hunt that only ever required the assessor to actually read the documentation in the first place). Second, it does not require realistic consideration of whether treatment is actually accessible, affordable, available in the participant’s region, or tolerable for that person. That is especially important because many disabled people are living on the Disability Support Pension, which for a single adult is about $31,223.40 a year, while others are trying to survive on much less, including JobSeeker. We still have the same rent, food, electricity, transport, and medical costs as everyone else, with disability- related costs added on top. A legal test that expects people to pursue thousands of dollars of treatment, equipment, travel, reports, or specialist care before they can access support is not grounded in economic reality. It is not reasonable to expect people on subsistence-level income support to privately fund endless attempts to prove they are disabled enough. Third, it risks turning any intervention that helps at all into evidence that the disability is not permanent enough, serious enough, or supportable enough.
The phrase “all appropriate treatment” is especially dangerous because it is so vague. If Parliament does not define it tightly, then disabled people are left at the mercy of decision-makers who may have wildly different ideas about what counts as appropriate, necessary, reasonable, available, or enough. That is not a theoretical concern. People with autism have already been subjected to fraudulent and abusive so-called “treatments,” including bleach products falsely promoted as cures. A law that makes access depend on whether “all appropriate treatment” has been tried
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
creates a dangerous opening unless it clearly excludes unsafe, pseudoscientific, coercive, inaccessible, or abusive interventions.
A disability can be permanent even if its effects can be partly alleviated. Equipment, medication, therapy, pacing, support workers, braces, wheelchairs, communication tools, and environmental changes may reduce the impact of disability without removing the disability itself. Someone with cerebral palsy may function better with a wheelchair, but that does not mean the underlying disability is no longer permanent. Someone with Ehlers-Danlos Syndrome may function better with mobility aids, therapy, pacing, and pain management, but none of that cures a genetic connective tissue disorder.
This is one of the most dangerous features of the Bill. It creates a risk that the better a disabled person manages their condition, the more the system will argue that they are less disabled, less permanent, or less eligible. It turns successful coping, adaptation, or assistive technology into something that can be used against the person rather than recognised as essential to their safety and participation.
In my own case, I have Ehlers-Danlos Syndrome. It took going to review and having even the NDIA’s own lawyers ensure that my evidence was finally considered properly before the Agency acknowledged that I had, in fact, tried what was available. But there is no cure for a genetic condition that causes faulty connective tissue. A standard that asks whether all appropriate treatment has been tried, without clear limits and safeguards, invites endless dispute, shifting goalposts, and arbitrary denial.
It is also not hard to imagine how this could be used in practice. A person could be told they must try every available treatment before access is recognised, then later be told that because treatment, equipment, or therapy alleviates some part of the impairment, they do not qualify for the supports they need. That is not a pathway to justice or sustainability. It is a loop designed to defer, deny, and exhaust.
This will hit rural and regional participants especially hard. Treatments may not exist locally, may have long waitlists, may not be affordable, or may not be clinically appropriate, yet the burden will still fall on the disabled person to prove a negative: that nothing else could materially help them. That is not a fair access test.
Parliament should be very careful before creating a legal test that asks whether all “appropriate treatment” has been tried, in a world where autistic people have already been subjected to bleach-based pseudoscience sold as treatment. Disabled people should never have to prove they rejected abuse in order to qualify for support.
Recommendation: The Senate should recommend removal or substantial amendment of the “all appropriate treatment” and “materially improve, reverse, or alleviate” provisions. At a minimum, the legislation should make clear that a condition can be permanent even where its impact is
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
partly alleviated by treatment, equipment, therapy, or support, and that access cannot be denied based on speculative, unavailable, unaffordable, unsafe, or inappropriate treatment options.
Issue 11: Reductions in Support, Social Isolation, and Ministerial Power My eleventh major concern is that the Bill deepens a system that already underestimates disabled people’s needs and then treats the resulting deprivation as acceptable. In practice, there is already a strong assumption within the NDIS that participants/allied health are overstating, exaggerating, or “padding” their support needs. That is profoundly dangerous when allied health professionals are usually asking for the bare minimum needed to keep a person safe and functioning.
The result is that many people do not receive the supports they actually need. In my own case, I received less than a quarter of what was identified as necessary, even though much of what was requested was aimed at slowing my decline and preventing more intensive and expensive needs in the future. That is not efficiency. It is short-sighted rationing that shifts the cost onto disabled people’s bodies, relationships, safety, and long-term outcomes.
This is already affecting my life in concrete ways. My social and community budget has been cut, which means I cannot go out and do the things I need to do, let alone build friendships or participate in ordinary social activities. Most of my current funding is already consumed by in- home care, grocery shopping, and medical appointments. More cuts would mean that the only people I ever see are my housemate, my support workers, and my allied health team, and even those supports are becoming harder to maintain within budget.
That is not community inclusion. It is managed isolation. A life in which a person is technically alive but unable to leave the house meaningfully, form relationships, or participate in the community is not a life that respects dignity, autonomy, or the purpose of the NDIS.
Group programs are not a universal answer. I am an adult, and it is demeaning to act as though I should only be allowed to leave the house in segregated disability group settings. I need 1:1 supports, I have my own interests, and my support time is often shaped by appointments and disability-specific needs that do not fit neatly into group activities. Forcing people into generic group models is not choice and control. It is a cheaper substitute for genuine participation.
I am also deeply concerned by the power this Bill gives for supports to be narrowed or reduced at a systemic level. It is not fair or safe for a minister to be able to cut funding for whole groups of disabled people as though we all fit the same template. We are not identical. We do not have the same bodies, the same risks, the same goals, the same interests, or the same support needs. A system that moves away from reasonable and necessary support and toward whatever the minister of the day is willing to allow is a system that places disabled people at the mercy of politics rather than need.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2471
For some people, that will mean more than inconvenience. It will mean deterioration, confinement, neglect, institutionalisation, and avoidable harm. In some cases, I believe it will contribute to deaths and firmly believe that it already has.
Recommendation: The Senate should recommend that the legislation prohibit across-the-board reductions in support categories for classes of participants, preserve genuinely individualised funding decisions based on reasonable and necessary need, and explicitly recognise social and community participation as essential to a safe and dignified life rather than an optional extra.
Conclusion This Bill does not secure the NDIS for future generations; it weakens it for the people who rely on it now. Across this submission, I have set out how these changes expand unchecked power, reduce transparency, narrow access, undermine individualised support, and make it easier for the Scheme to delay, deny, or remove the assistance disabled people need to live safely and with dignity
The NDIS was meant to support disabled people to participate in the community, exercise choice and control, and live ordinary lives. This Bill moves in the opposite direction by making support more conditional, more politicised, more bureaucratic, and less responsive to the realities of disability. It risks leaving people trapped in isolation, deterioration, and crisis, while calling that sustainability.
Disabled people are not a budget problem to be managed. We are human beings with lives, relationships, goals, and rights, and legislation that ignores that reality will cause profound harm. The Senate should reject this Bill, or at the very least recommend substantial amendments so that disabled people are not forced to pay for administrative convenience and political cost-cutting with our safety, autonomy, and survival.
If this Parliament passes laws that make it harder for disabled people to access support, easier to cut what keeps us alive, and harder to challenge bad decisions, then it should be honest about the consequences: those consequences will be harm, abandonment, and preventable deaths.