Submission to NDIS Reform Enquiry

Submission 2513

Subject: Securing the NDIS Safely - Response to NDIS Bill, Submission to Enquiry

Minister for Health and Ageing, Disability and the National Disability Insurance Scheme the

Hon Mark Butler, Minister for the National Disability Insurance Scheme Senator the Hon

Attention:

Jenny McAllister, and the Minister for Employment and Workplace Relations, The Hon

Amanda Rishworth MP

Policy Context: Reform to the NDIS Bill impacting funding, viability, converging reform and

Our position Support reform. Deliver it safely. Australia needs an NDIS that is financially sustainable, delivers quality outcomes for participants, protects public confidence and directs funding to those who need it most. Reform is necessary, and it is expected.

Reforms of this scale must not transfer unacceptable risk onto participants, families, communities, states or the not-for-profit providers who deliver essential supports. Sustainability cannot be achieved by shifting risk onto others before the systems meant to replace today’s supports actually exist.

The governing principle: no reduction, reassessment, exit, budget reset or service withdrawal should occur until replacement supports are funded, operational, locally available and independently tested.

What we ask of government

Sequence the reforms. Publish a binding rollout roadmap so that no cost or revenue change commences before the supports it depends on are funded, operational and locally available. (Disability and Employment portfolios)
Fund the transition. Provide transitional funding for providers absorbing new wage, pricing and compliance costs at the same time, so viable services are not lost during the change. (both portfolios)
Close the price-to-wage gap. Bind NDIS price indexation to actual award wage movements, end the support coordination price freeze, and tie any new ministerial pricing power to a transparent, published cost model. (Disability)
Protect community connection. Stage or pause the 1 October 2026 budget resets until Foundational Supports and the Inclusive Communities Fund are operating, locally available and independently evaluated. (Disability)
Solve supported employment funding. Deliver a distinct funding mechanism so the higher wage floors in supported employment, which are right for workers, do not make the organisations employing them insolvent. (Both portfolios)
Resource the home and living transition. Fund realistic timelines for supported independent living registration and the new practice standards, and deliver the promised differentiated pricing for complex needs. (Disability)
Safeguard viability and choice. Build provider-viability tests and participant review rights into commissioning, and treat forced mergers and service closures as a loss of essential capacity, not a neutral efficiency. (both portfolios)

Amplify Alliance | Disability | NDIS Reform Bill Submission  1

Submission 2513

Why this brief, and why now Five reform tracks are landing on one sector inside roughly eighteen months. Each is being run by a different body, across two portfolios, and no one holds the cumulative impact.

Taken one at a time, each change is defensible. Taken together, with no shared sequence and no transitional funding, they are pushing financially sound providers from surplus into deficit. The timing is the problem, not any single measure.

The window is now. The Securing the NDIS for Future Generations Bill is before the Senate, the committee reports on 14 August 2026, and consultations on home and living commissioning, the Inclusive Communities Fund and differentiated pricing all open in July 2026.1

The convergence map

When        What lands                                                           Portfolio

Supported Employment Services Award transitional wage

30 Jun 2026 Employment increases take effect.

Minimum wage and award increases (awards +4.75%, National Minimum Wage +6%). SIL providers must register; new SIL Employment / 1 Jul 2026 practice standards begin. Consultations open on home and living

Disability

commissioning, the Inclusive Communities Fund and differentiated pricing.

SCHADS Award rates rise again, lifting the disability support wage 1 Aug 2026 Employment bill a second time in the same quarter.

Senate committee reports on the Securing the NDIS for Future 14 Aug 2026 Disability Generations Bill.

NDIS budget resets: social, civic and community participation cut 1 Oct 2026 Disability 50% on average, capacity-building daily activities cut 10%.

New planning framework and tighter eligibility assessments 2027 Disability phase in; plan-management commissioning begins.

Foundational Supports fully implemented; new eligibility

By Jan 2028     boundaries apply to new entrants; Thriving Kids replaces NDIS     Cross-government

access for some children.

1 National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026, introduced 14 May 2026; Senate Community Affairs Legislation Committee report due 14 August 2026.

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What government is trying to achieve, and where the assumption breaks Across both Labor and Coalition governments, the objectives have been remarkably consistent:

reduce the growth trajectory of NDIS expenditure
increase participant choice and competition
reduce reliance on block-funded services
encourage innovation through market competition
remove providers that cannot demonstrate value
strengthen safeguards against fraud and poor quality
encourage providers to become more commercially sustainable. None of these objectives is unreasonable.

The objectives are understandable. The implementation assumptions are flawed.

The flaw is a single assumption: that a social market behaves like a commercial one. It does not. Disability services carry the features economists call thin markets and market failure. Providers cannot withdraw from unprofitable participants, relocate to higher-demand areas, automate much of their delivery, rapidly lift productivity, or substitute technology for the workforce. They keep delivering because, very often, there is no one else who will.

This matters most for sequencing, because in a normal market, if a business leaves, another one takes its place, in a thin market, as in the current disability services market, when a provider leaves, usually no one replaces them. So that exit is permanent. When a provider of last resort withdraws, no new entrant is waiting behind them, and the capacity does not return when the policy is later corrected. An out-of sequence reform is therefore not a cost. It is an irreversible loss of essential capacity.

This is not an argument against the market. The NDIS was built as a market by design: individualised funding, choice, control and provider competition were chosen deliberately in 2011.2 These reforms intensify market discipline within that design. The issue is not anyone’s intent. It is that commercial disciplines are being applied to a market that cannot ever behave like a fully commercial one.

Reform succeeds when government and providers adapt together.

Well-run organisations will adapt, innovate and lift productivity, and many already are. No amount of operational excellence, though, can offset settings that unintentionally create market failure, remove essential capacity, or push costs elsewhere in the public system. Government’s responsibility is to sequence, fund and test before it withdraws. That reciprocity is the deal: providers carry their share of the change, and government carries its share of the design.

2 Productivity Commission, Disability Care and Support (2011): the NDIS was designed as an individualised-funding market built on participant choice, control and provider competition.

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The converging reforms, lever by lever Each lever below sets out what is changing, the commercial impact on organisations, the impact on participants, and Amplify’s position.

4.1 Wage increases

Award wages rose 4.75% and the National Minimum Wage 6% from 1 July What is changing 2026.3 SCHADS support-worker rates rise again on 1 August 2026,4 and Supported Employment Services Award rates lifted on 30 June 2026.5

Labour is the dominant cost in disability services. Two award movements Impact on inside one quarter raise the wage bill while revenue is fixed by NDIS price organisations caps. The increases are right for workers; the funding to carry them has not moved in step.

Impact on Where margins vanish, providers reduce hours, drop thin services or exit. participants Participants feel it as reduced availability, not as a pay line.

Support fair wages. Index the funding that pays for them to the actual Amplify’s position award movements, in the same year they take effect.

4.2 NDIS pricing and the price-to-wage gap

NDIS price limits are set by the agency and have lagged wage growth; support What is changing coordination prices have been frozen since 2019-20.6 The Bill would give the Minister power to set prices by determination. 7

When the price cap rises more slowly than the wage floor, margin is Impact on compressed by design. A multi-year freeze on support coordination has organisations already made that service uneconomic for many providers.

Squeezed prices push providers toward the simplest, lowest-cost supports Impact on and away from participants with complex needs, the exact people the scheme participants exists to serve.

Bind indexation to real award movements, end the support coordination Amplify’s position freeze, and tie any ministerial pricing power to a transparent, published cost model.

3 Fair Work Commission, Annual Wage Review 2026 (decision 2 June 2026); Fair Work Ombudsman, minimum wage increase from 1 July 2026. 4 Fair Work Ombudsman, SCHADS Award (MA000100) pay arrangements; further increase effective 1 August 2026. 5 Fair Work Ombudsman, Supported Employment Services Award (MA000103); transitional minimum-rate increases for Grades A and B from 30 June 2026, plus the 1 July 2026 review increase. 6 NDIA, Annual Pricing Review and Pricing Arrangements and Price Limits 2025-26: disability support worker price limits indexed 3.95%; support coordination price limits unchanged since 2019-20. 7 NDIA pricing updates: the Bill proposes to give the Minister for the NDIS power to make a pricing determination; the Annual Pricing Review would inform that advice.

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4.3 The 1 October 2026 budget resets

From 1 October 2026, budgets for social, civic and community participation What is changing are cut 50% on average and capacity-building daily activities 10%, resetting toward 2023 spend.8

This is a direct revenue strike on day programs and group supports, often a Impact on provider’s most reliable income. It removes income the same year wage costs organisations rise twice. This single change explains much of the surplus-to-deficit swings members are reporting.

Community participation is where inclusion actually happens: connection, Impact on routine, social contact and a path toward work. Cutting it before the participants replacement exists risks isolation, not saving.

Stage or pause the resets until Foundational Supports and the Inclusive Amplify’s position Communities Fund are operating, locally available and independently evaluated.

4.4 Supported employment and Australian Disability Enterprises

Supported employment wage floors are rising as the sector moves to higher What is changing minimum rates, 9while NDIS supports-in-employment funding has not been redesigned to match.

Supported employment providers must pay lawful, higher wages to workers Impact on whose assessed productivity has not changed, against a funding model built organisations for the old wage structure. The result is structural loss, not inefficiency.

These workers are employees with disability. If the organisation that employs Impact on them fails, they lose the job, the income and the social participation that participants came with it.

Deliver a distinct funding mechanism so higher wage floors, which are right Amplify’s position for workers, do not make supported employment insolvent.

8 Department of Health, Disability and Ageing, About the changes to the NDIS: from 1 October 2026, social, civic and community participation budgets reduced 50% on average and capacity-building daily activity budgets 10%, resetting spend toward 2023 levels. 9 Fair Work Ombudsman, Supported Employment Services Award (MA000103); transitional minimum-rate increases for Grades A and B from 30 June 2026, plus the 1 July 2026 review increase.

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4.5 Supported independent living and home and living reform

Supported independent living (SIL) providers must register and meet new What is changing practice standards from 1 July 2026, with home and living commissioning consultation opening in July 2026.10

New registration and standards arrive with a short runway and real Impact on compliance cost, layered on top of the wage and pricing pressures already organisations landing. Differentiated pricing for complex needs has been promised but not yet delivered.

Stronger safeguards in shared accommodation are welcome and overdue. Impact on They protect participants only if the providers expected to meet them remain participants viable.

Fund realistic timelines for registration and the new standards, and deliver Amplify’s position the promised differentiated pricing for complex needs.

4.6 Foundational Supports, eligibility and Thriving Kids

Foundational Supports ($10 billion over five years) and Thriving Kids will sit What is changing outside the NDIS, with eligibility shifting toward functional-capacity assessment and full implementation by January 2028.11

Whole cohorts may move out of the NDIS before the services meant to Impact on receive them are built, funded or locally available, leaving providers planning organisations against an unknown future caseload.

Impact on Done well, this gives more people timely support. Done out of sequence, it participants removes a person’s current support before a tested replacement exists.

No participant should lose NDIS access until Foundational Supports are Amplify’s position funded, operational, locally available and independently tested.

10 NDIS Quality and Safeguards Commission: SIL provider registration and new SIL Practice Standards from 1 July 2026; Department of Health, Disability and Ageing: consultation on commissioning home and living supports from July 2026. 11 National Cabinet and Department of Health, Disability and Ageing: Foundational Supports, $10 billion over five years (Commonwealth and states), full implementation by January 2028; Thriving Kids; transition toward functional-capacity assessment.

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Submission 2513

Provider viability: what members are reporting The evidence below is aggregated and de-identified from conversations across Amplify’s membership. It describes a pattern, not any single organisation.

The sector-scale picture Amplify’s member reports sit inside a sector-wide squeeze. The regulator’s latest data shows charity revenue at a record $239 billion, but expenses growing faster than revenue (8.6% against 7.5%), driven by a 10% rise in employee costs, now around 56% of all sector spending. Government provides close to half of that revenue, about $118 billion.12 Rising labour cost against constrained, government-set revenue is the squeeze, visible in the national accounts before it reaches any single organisation.

The pattern

The pattern is not unique to Amplify. Disability enterprise leaders reported commercial fragility now a critical issue, and discussed openly at sector forums (2ig, 2026).
NDS State of the Sector Report FY25 48% of providers reported a loss, a further 15% broke even.
Organisations moving from a multi-million-dollar surplus to a comparable deficit within a single financial year, a swing of close to four million dollars in the sharpest cases reported.
Boards now reviewing which services to scale back or close, with community participation and supported employment most exposed.
A wave of mergers and acquisitions, as smaller and specialist providers seek shelter at scale simply to keep serving participants.

The mechanism

The cause is not poor management. It is revenue capped below cost growth, the 1 October resets removing day-program and group income, and new compliance cost, all arriving together. Survival increasingly depends on reaching the scale at which back-office and corporate costs can be spread across far more participants.

Why consolidation is not a free efficiency

Government may welcome consolidation as the market becoming more efficient. The cost sits elsewhere: lost local presence, the disappearance of specialist and values-driven providers, narrower choice for participants, and thin-market failure in regional and remote communities where one provider leaving means no provider at all. A market designed for choice does not deliver choice once it has consolidated to a handful of large operators.

12 Australian Charities and Not-for-profits Commission, Australian Charities Report, 12th edition (2024 reporting period, released June 2026): sector revenue $239 billion (up 7.5%); expenses $231 billion (up 8.6%); employee expenses $128 billion (up 10%, around 56% of expenses); government revenue approximately $118 billion, more than 49% of the sector total.

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Submission 2513

What we are asking Amplify supports a sustainable, safe and high-integrity NDIS. Sustainability, though, cannot be achieved by shifting risk onto participants, families, states, communities or not-for-profit providers before replacement systems exist.

The Bill should not proceed or commence in its current form unless Parliament locks in the sequencing, safeguards, funding, review rights and transition arrangements that protect participants and preserve viable service capacity. Reform that meets those conditions will have Amplify’s active support.

Reform that protects people protects providers, and reform that does neither is not sustainability, it is risk transfer with a different name.

Prepared by National Disability Advocacy & Policy Advisor, Wendy Bezzina

Date 25 June 2026

Endorsed by CEO Amplify Alliance, Debra Cerasa

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