Submission to the Senate Community Affairs Legislation Committee: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 2514

Submission to the Senate Community Affairs

Legislation Committee

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for

Future Generations) Bill 2026

Committee Secretary

Senate Standing Committees on Community Affairs

PO Box 6100, Parliament House, Canberra ACT 2600

community.affairs.sen@aph.gov.au

Dear Committee Secretary,

I am an Occupational Therapist and the Director of Spectrum Therapy WA, a multidisciplinary allied health practice providing therapy supports to NDIS participants in Western Australia. We are a NDIS registered company and have been since 2020. We employ occupational therapists, speech pathologists, physiotherapists and therapy assistants. We support children, adolescents and young adults with complex needs and disabilities, including physical, cognitive and neurodevelopmental disability.

I write in two capacities. As a clinician, I assess functional capacity, deliver therapy and prescribe customisable assistive technology, and I have written the reports this Bill directs decision-makers to discount. As a business owner, I employ the clinicians who write them.

My primary concern is not for my practice but for the people we support.

The therapy supports we deliver are funded from the Capacity Building Daily Activities budget. That is the budget line the Government proposes to reduce across every Participant’s plan. So when I write about that reduction at section 3.2, I am not writing about revenue. I am writing about the child who cannot see a physiotherapist often enough, whose joints are quietly contracting while she waits, and for whom the window in which that is reversible is closing; the child who cannot get an occupational therapist to assess and prescribe the assistive technology he needs in order to move, to toilet, to shower, to sleep

Spectrum Therapy WA | juliana@spectrumtherapywa.com.au

Submission 2514

Submission — NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026

and to play, and who will go without it not because it was refused but because nobody was funded to assess the need, trial the equipment, and write the report; and the child whose complex communication needs require regular speech pathology to build and maintain an AAC system, and who, without it, will simply stop being able to tell anyone what she wants, what hurts, or what has happened to her.

None of these children will appear in a Budget paper. Their costs will appear later, and elsewhere, in the surgeries that contractures and postural deformities make necessary, in the hospital admission to treat the broken bone from a fall that could have been prevented, in the supported accommodation that a young person enters years earlier than they needed to, in the behaviours that emerge when a child has no way to be understood. These are not projections. My team is already seeing what happens when supports are withdrawn without warning, and what I describe at section 4.1 is reported to me by the 11 allied health therapists within my company who support NDIS participants. The people who bear the most severe consequences of this Bill will not be Providers. They will be the Participants whose functional capacity declines while Parliament is assured that nothing essential has been touched.

I do not dispute that the NDIS growth trajectory needs attention. I do dispute though that this is how you address it. I support a financially sustainable NDIS. Sustainability, however, is not achieved by legislating that people receive less support than they need, supports than are essential for their safety, access and participation in everyday life. That is not sustainability. It is cost-shifting, onto families, onto hospitals, onto state services, onto the unpaid labour of carers who are overwhelmingly women, and onto the bodies and minds of people with disability themselves.

My central objection to this Bill is structural. It transfers decisions that are currently clinical, individualised and reviewable into the hands of a single Minister, exercised through legislative instruments that no Participant can challenge. It then instructs decision-makers to use generalised research over the clinical judgement of the qualified treating practitioner who has actually assessed the person. Taken together, these changes sever the connection between a person’s assessed need and the support they receive.

I turn to the amendments, because the Committee should be clear about what has actually changed and what has only been announced.

On 23 June 2026 the Government and the Australian Greens announced an agreement, accompanied by the eight-week extension of this inquiry. The Greens described that agreement as limiting the Ministerial power to reduce funding across support categories, requiring that any treatment a person must undertake be publicly funded and not a restrictive practice, requiring greater transparency around automated decision-making, and reducing the transitional rule-making period from twelve months to six for most of the Bill. However, the amendments that the Government has circulated, in the Supplementary Explanatory Memorandum of 1 July 2026, do none of those things. They do three things:

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they define what counts as a reasonable attempt to contact a participant before a plan is suspended or revoked; they remove an ambiguity in the permanence provisions by omitting paragraphs 24(5)(b) and 25(1B)(b); and they refine the plan management provider panel. The Supplementary Explanatory Memorandum records that the amendments “will not alter financial impact of this Bill” and “do not impact the Bill’s compatibility with Human Rights”.

Section 34A is untouched. Schedule 5 is untouched. The automation provisions are untouched. Nothing in the circulated amendments protects any category of support from a support determination, and nothing requires that treatment be publicly funded or free of restrictive practice.

I do not say the announced amendments will not be moved. They may be moved in the Senate, and I would welcome those that protect Participants. But this Committee is reporting on the Bill as it stands, and as it stands the provisions that concern me most have not been amended at all. I ask the Committee not to treat an announcement as though it were a statute. The disability community has been invited to take comfort from protections that, seven weeks after they were announced, exist in a media release and not in the Bill.

Of the amendments that have been circulated, the suspension provisions are a genuine improvement and I acknowledge them. The permanence amendment is narrower than the Greens’ description suggests: it corrects a drafting problem, and leaves the ‘all appropriate treatment’ requirement in place.

The support determination carve-outs leave exposed the very two categories the Government has actually announced it will cut: social, civic and community participation, and capacity building. Capacity Building Daily Activities, despite the similarity of its name to the protected Core category ‘Daily Living’, sits behind no firewall at all. The Committee’s own Recommendation 2 confirms this, seeking clarification of “the critical supports which will not be impacted through the proposed reduction to social, civic and community participation and capacity building support budgets”. The transitional rule-making carve outs preserve the full twelve-month power over New Framework Planning, Reasonable and Necessary, and Plan Renewals, the three most consequential parts of the Bill. Each concern set out below survives the amendments.

I have read the Committee’s interim report of June 2026. It makes four recommendations, and I ask the Committee to look plainly at what they do. Not one of the four recommendations would change a single word of the legislation before this Parliament.

That result sits uneasily with the Committee’s own findings. Recommendation 2 asks the Government to explain, among other things, “the mechanism through which the Minister must have regard to the safety of participants when making a support determination, including safeguards and monitoring”, and “the critical supports which will not be impacted” by the proposed reductions. The Committee has therefore identified that the Bill’s safety mechanism is unclear, and that it cannot presently say which supports are protected. Those

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are gaps in the statute. The Committee proposes to fill them with paragraphs in an explanatory document that no participant can enforce and no court is bound by.

Whilst there is a safeguard on the face of the power, it is limited to a single sentence. The proposed subsection 34A(3) states, “In making the determination, the Minister must have regard to the safety of participants.” That is the whole of it.

A duty to have regard to something requires a decision-maker to turn their mind to it. It does not require them to conduct any particular assessment, or to reach any particular conclusion. A Minister who considers whether halving a support category will place participants at risk of neglect, crisis or loss of essential functioning, concludes that it will, and proceeds regardless, has still complied with subsection 34A(3). Nothing in the provision requires an individual reassessment, a functional analysis, a safeguarding step, or the identification of a single participant who might be harmed. And because the determination takes effect as a legislative instrument, no participant has standing to argue in a tribunal that the Minister’s regard was inadequate.

This is what the Committee’s Recommendation 2 is really asking about when it seeks clarity on “the mechanism through which the Minister must have regard to the safety of participants”. The answer, on the face of the Bill, is that there is no mechanism. There is a state of mind. The Committee proposes to supply the missing machinery through paragraphs in the Explanatory Memorandum.

An Explanatory Memorandum is not law. A court may consult it to resolve an ambiguity in the statutory text; it cannot create an obligation the Act omits, nor confine a power the Act confers. A participant cannot enforce it. A successor Minister does not inherit it. And it can be amended at will, which is precisely what Recommendation 2 asks the Government to do. A safeguard described in a document that may be rewritten without Parliament is not a safeguard. It is an assurance about how a power is presently intended to be used, and assurances do not survive a change of Minister.

If Parliament is satisfied that participant safety must constrain this power, that constraint belongs in the Act as a condition on its exercise. The Minister must not make a determination unless satisfied that no participant will be placed at risk of neglect, crisis or loss of essential functioning, so that a determination made without it is invalid, and someone may say so before a court. If Parliament is satisfied that certain critical supports will not be cut, that protection belongs in the Act as an exclusion. Everything short of that leaves the power exactly as drafted.

I make this submission in the respectful hope that the final report will reach a different conclusion. The Committee received more than 4,000 submissions and approximately 250 further short statements of concern. The Government’s own NDIS Reform Advisory Committee has warned the package would cause material harm.

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Summary of recommendations Provision Concern Recommendation
1. Sch 1, Item 66 Repeal removes the Act’s only principles Retain s 31. Strike out Item 66.

(repeals s 31) governing how a plan is made, varied, reassessed and replaced: individualisation, direction by the participant, the right to exercise control over one’s own life, choice and independence. Only three of eleven principles are carried into s 17A(3).

2. s 17B             A duty to prioritise Scheme sustainability,   Amend s 17B so that financial sustainability,

left unqualified, will over time displace the while a relevant consideration, cannot override entitlement to reasonable and necessary a participant’s entitlement under s 34. supports that sits beside it.

3. s 34A                 Permits the Minister to reduce funding for    Delete s 34A in full.

a group of supports across the Scheme by legislative instrument, without individual reassessment. Not a reviewable decision. Sub-s 34A(5) provides the determination has effect even where funding falls below the cost of a reasonable and necessary support. Sunsetting does not apply.

4. s 34A(3)            The sole safeguard is a duty to ’have regard   Enact the safeguards in the Act: the safety

(and interim report      to the safety of participants’. A Minister       obligation, and the identification of critical

Rec 2)              may consider the risk of neglect, crisis or     supports that may not be reduced, as

loss of essential functioning, conclude it enforceable provisions. exists, and proceed. The Government has answered the Committee by amending the Explanatory Memorandum, not the Bill.

5. s 34A             No published impact assessment,                   If s 34A survives, require: a published

(if retained)              consultation, disallowance or audit          independent human rights and safeguarding

conditions the exercise of the power. impact assessment; genuine consultation; disallowance; Category A Rule status; and ongoing independent audit.

6. ss 33(2EA), 33(2EB)    Permits the Minister to cap funding         Remove, or at minimum provide a mandatory,

amount, intensity, duration and worker-to- individually reviewable clinical exemption participant ratios. Ratio caps override pathway. clinical risk assessments made by practitioners who have seen the participant.

7. ss 34(1E)-(1F)         Requires generalised peer-reviewed        Remove ss 34(1E)-(1F).

research to be preferred over the treating practitioner’s judgement and the participant’s lived experience. Inverts evidence-based practice, and disadvantages cohorts excluded from trials.

8. s 9B                  Defines functional capacity and permits     Amend s 9B so capacity is assessed in real-

Rules to set the criteria and tool by which it world conditions, accounting for environment, is measured, including for existing assistive technology, executive function, participants. A single instrument cannot fluctuation and cumulative impairments. Sub-s capture fluctuating, episodic or masked 9B(2) must not permit one tool to determine presentations. access.

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Provision              Concern                             Recommendation

9. Sch 1, Items 88-94;   A person must undertake all appropriate    Amend so treatment must be evidence-based,

s 25A                   treatment; a treatment they cannot reach     clinically indicated, obtainable in practice,

is deemed available (reversing Davis); affordable and freely consented to. Protect the declining treatment for non-medical right to decline treatment without losing reasons bars access. Applies to early access. intervention.

10. s 25B               Another service system may bar access to   Amend so another system bars access only

the Scheme, reversing Sutherland. Rules where its support is shown to exist, be may exclude further groups, including aged reachable, timely, culturally safe and care recipients - engaging First Nations substantially equivalent. people eligible at 50.

11. s 34(1)(aa)          Supports must arise ’directly’ from an      Remove s 34(1)(aa).

impairment meeting the access criteria, undoing the whole-of-person approach enacted in 2024 and confirmed in Eastham.

12. ss 34(1G)-(1J)       Presumes parents provide substantial      Amend to require consideration of family

supervision, personal care, transport, sustainability, child wellbeing, cumulative emotional and behavioural support, while caring burden, parental disability, and the omitting the Rules factors that make the comparative cost of withdrawing the support. presumption fair. Transfers unpaid care to women.

13. ss 47, 47A, 48        Determinative decisions reducing funding    Require advance notice and purpose; a support

are made without notice, without the person; participant-led evidence; documented participant’s evidence, without regard to consideration of clinical material on file; reports on file, and without written written reasons; and a right of review. reasons. This is already occurring.

14. s 47A            A request to vary a plan to fund assistive    A request to fund a specific support must not

technology becomes the occasion to operate as an occasion to reduce other reduce funding elsewhere. Participants supports in that plan. learn not to ask.

15. Sch 1, Items 21-25;   Appeal rights removed; plans suspended     Restore the appeal rights; narrow suspension;

s 40A                where a participant is ’uncontactable’. The    require accessible contact; and require a

July amendments define contact attempts documented safeguarding review before but impose no duty to investigate suspension. hospitalisation, custody or homelessness, and require no safety assessment.

16. s 48A                Participant-requested reassessment           Insert an urgent reassessment pathway,

(reassessment)           limited to significant and ongoing change;    decided within 21 days, on the triggers

Agency decision period extended from 21 submitters identified at para 2.141 of the to 90 days. Psychosocial deterioration can interim report. be rapid and critical to life.

17. ss 59B-59E         Automated administrative action,             Prohibit deciding eligibility or funding by

expandable by Ministerial instrument. machine alone. Publish the logic, calculations Merits review is preserved only where it and assumptions. Guarantee human review. already exists - so unreviewable decisions Require independent audit and parliamentary remain unreviewable when automated. scrutiny before any expansion.

18. s 45C              The Minister sets maximum prices,          Replace with independent pricing by the

departing from Recommendation 11 of the Independent Health and Aged Care Pricing NDIS Review. The purchaser also holds the Authority, set against the true cost of safe Budget line. delivery and rural workforce shortages.

19. Sch 2                 Investigation powers and civil penalties      Apply proportionately, transparently and in a

(fraud and              extend to participants. Disability itself is      trauma-informed way, with accessible

compliance)             frequently the reason a person cannot       pathways, independent oversight, funded

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Provision              Concern                             Recommendation

respond, document or comply in time. advocacy, bounded nominee liability, and Nominee liability falls on unpaid family. statutory recognition that disability may affect capacity to comply.

20. ss 45A(5)(a), 45B,    Claim window cut from two years to 90       Retain a workable claim window; remove the

182(4)                   days; seven-year record-keeping; a strict-      strict-liability debt; impose statutory limits and

liability debt with no defence where a confidentiality protections on demands for record is absent; and no limit on demands clinical records; guarantee supports continue for clinical therapy records. while a claims dispute is resolved.

21. Sch 4                Standardised budgeting risks replacing       Retain person-centred planning. Prohibit

(new framework          individual assessment of reasonable and      standardised rationing replacing individual

planning)               necessary supports.                        assessment. Preserve lived-experience and

practitioner evidence. Publish the tools and the budgeting method.

22. ss 32J, 32K         The method by which an assessment         State the budget-setting principles in the Act:

becomes a dollar figure sits in delegated transparency, fairness, proportionality, instruments; the principles governing it sit consistency between participants with similar nowhere. needs, and sound fiscal management.

23. s 99                Support determinations, caps, automatic     Provide that any decision or instrument

(reviewability)           plan renewals and transitions to new          materially reducing a participant’s supports or

framework plans each reduce supports and funding is a reviewable decision, with written none is reviewable. The same outcome is reasons, a right to submit participant-led contestable by one route and not another. evidence, and access to a fresh assessment by a different assessor.

24. s 32L;            A participant may not receive the           Guarantee a full copy of any assessment report

s 32BA                 assessment report that determines their     and an opportunity to comment before

plan, nor know which impairments are finalisation. Provide the notice of impairments recognised before being assessed against well before any assessment, planning process them. or reassessment.

25. Sch 5, Item 1       A Henry VIII power permitting the Minister   Remove Sch 5, Item 1. If retained, subject it to

to modify the operation of the Act by rule. parliamentary oversight, consultation, The announced six-month limit does not published impact assessments and appear in the circulated amendments, and independent review, and apply the six-month would in any event preserve twelve limit to every Schedule without exception. months over Sch 4 and Sch 1, Parts 5 and 6

planning, reasonable and necessary, and plan renewals.
1. Capital carve-out Assistive Technology and Home Extend any protection given to Assistive
vs Capacity Building Modifications are protected, but the OT Technology and Home Modifications to the

and physiotherapy assessment and clinical assessment and prescription through prescription required to obtain them are which those supports are obtained. funded from Capacity Building Daily Activities, which is not. The item stays fundable in principle and unobtainable in fact.

27. Announced cuts    A 50 per cent reduction to social, civic and   Remove the immediate cuts from the reform

(SCCP; Capacity        community participation and a reduction     package.

Building) to Capacity Building Daily Activities deliver

$13.2bn of savings - one third of the total while fixing none of the Scheme’s structural problems (Grattan Institute).

28. The Bill as a whole   The Parliamentary Joint Committee on      The Bill should not proceed as drafted.

Human Rights has found the Bill may limit Commencement should await genuine the rights of persons with disability, to an consultation; the Minister’s response to Report

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Provision              Concern                             Recommendation

adequate standard of living and health, 6 of 2026 and the Committee’s concluded and the rights of the child, and that it ’has assessment; a published gender impact not been demonstrated’ that the analysis; and foundational supports that exist, conditions for a retrogressive measure are have been independently evaluated and shown met. to work.

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The Concentration of Power in the Minister The Bill creates at least four distinct mechanisms by which a Minister may, acting alone and through instruments that are not individually reviewable, reduce the supports a person receives. Each is significant. Together they are, in my view, constitutionally and ethically untenable in a scheme built on individualised entitlement.

3.1 Support determinations — Proposed section 34A

Proposed section 34A permits the Minister to make determinations reducing, by percentage, the funding available for specified groups of supports across the entire Scheme. Critically, proposed subsection 34A(5) permits such a determination even where the remaining funding is less than the full cost of the participant’s reasonable and necessary supports.

This should be stated plainly, because the Explanatory Memorandum does not obscure it: the Bill authorises the Commonwealth to assess a person as needing a support, and then to decline to fund that support in full. The Explanatory Memorandum’s own worked example describes a participant assessed as requiring $44,000 in community supports whose actual funding is limited to $30,000.

This reverses McGarrigle v National Disability Insurance Agency [2017] FCA 308, in which the Federal Court confirmed that the NDIS must fully fund a participant’s reasonable and necessary supports. The words ‘reasonable and necessary’ are not decorative. If a support is necessary and the Scheme does not fund it, the need does not evaporate. It is met by family, or it is met in an emergency department, or it is not met at all.

Because determinations operate as legislative instruments, the resulting reduction is not a reviewable decision. A participant cannot appeal it. This removes, at a stroke, the administrative law protections that have been the Scheme’s principal accountability mechanism since 2013.

The Bill does not leave this to inference. Proposed subsection 34A(5) provides: “To avoid doubt, the determination has effect even if the result is either or both of the following: (a) the funding provided under a participant’s plan for a reasonable and necessary support is less than the total cost of the support; (b) the funding provided under a participant’s plan for all reasonable and necessary supports funded under the plan taken as a whole is less than the total costs of the supports.”

I would ask the Committee to sit with that subsection. Parliament is being invited to enact, for the avoidance of doubt, that a person may be assessed as needing a support and then not be given enough money to buy it. The phrase ‘reasonable and necessary’ survives in the Act. What is removed is any obligation to fund it.

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Two further features of the provision deserve attention. Proposed paragraph 34A(1)(a) requires only that the percentage be ‘lower than 100%’. Nothing in the Bill limits a determination to the 50 per cent the Government has announced; a future Minister could reduce a funding component by any proportion short of extinguishing it entirely. And the note to subsection 34A(1) records that the sunsetting provisions of the Legislation Act 2003 do not apply. Legislative instruments ordinarily expire after ten years, requiring a government to revisit them. A support determination does not. Once made, a cut endures until a Minister chooses to lift it.

3.1.1 Which supports may be reduced

The Bill does not say which supports a determination may reach. Proposed paragraph 34A(1)(a) refers only to ‘a specified group of supports’. The phrase is not defined or limited anywhere in the Bill.

The Explanatory Memorandum supplies the list. At page 25 it explains that groups of supports “are the categories of supports that appear in participant plans and include” the

Community Participation; Consumables; Transport; Home and Living; Young People in

Residential Aged Care. Under Capacity Building: Behaviour Support; Improved Living

Arrangements; Increased Social and Community Participation; Finding and Keeping a Job;

Relationships; Health and Wellbeing; Lifelong Learning; Choice and Control; Improved Daily

Living Skills; Support Coordination and Psychosocial Recovery Coaches. Under Capital:

Assistive Technology; Assistive Technology Maintenance, Repair and Rental; Home

Modifications; Specialist Disability Accommodation.

Two observations follow, and I ask the Committee to weigh both.

First, the word is ‘include’. The list is illustrative, not exhaustive, and it appears in explanatory material rather than in the Act. The Minister’s power under subsection 34A(1) is not confined by it.

Second, the amendments agreed in June 2026 remove five categories from the power: Daily

Living, Transport, Consumables, Assistive Technology and Home Modifications. Everything

else on that list remains exposed. That includes the whole of Capacity Building — every category from which therapy, behaviour support, employment support and support coordination are funded. It includes Home and Living. It includes Specialist Disability

Accommodation. It includes Young People in Residential Aged Care, and Assistive

Technology Maintenance, Repair and Rental.

I want to name the consequence for the participants I see. A determination could reduce Behaviour Support for a person whose behaviour support plan is the reason they still have a tenancy. It could reduce Support Coordination and Psychosocial Recovery Coaches for a person with psychosocial disability whose recovery coach is the only reason they engage with the Scheme at all — and who, under the Bill’s suspension provisions, becomes

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‘uncontactable’ without them. It could reduce Finding and Keeping a Job. It could reduce Improved Daily Living Skills, which funds the occupational therapy, speech pathology and physiotherapy my practice delivers. None of these reductions would require anyone to assess the person affected.

The Committee’s Recommendation 2 asked the Government to clarify “the critical supports which will not be impacted”. Read against the Explanatory Memorandum’s list, the honest answer is that the Bill protects none of them. It permits a Minister to choose.

3.1.2 The Government’s answer, and what it demonstrates

On 1 July 2026 the Government circulated an Addendum to the Explanatory Memorandum, responding to the concerns raised in the Committee’s interim report. I have read it, and I ask the Committee to notice what it is.

It is an amendment to the Explanatory Memorandum. Not one word of the Bill has changed. The Committee identified that the safety mechanism in subsection 34A(3) was unclear, and that it could not say which supports were protected. The Government has answered by inserting paragraphs into an explanatory document.

Consider what those paragraphs say. The Addendum states that a support determination “is not intended to affect supports that are essential to a participant’s health, safety or continuous care needs”. Not intended. Subsection 34A(5) provides that a determination has effect even where the funding left is less than the cost of a reasonable and necessary support, and nothing in the Bill exempts a support because it is essential to a person’s health or safety.

The Addendum states that the power “is confined to specified support categories, such as social, economic and community participation and improved daily living skills”. The word ‘confined’ is doing work the Bill does not support: subsection 34A(1) confines nothing, and the words ‘such as’ concede that the categories named are examples. The sentence does, however, confirm in the Government’s own words that improved daily living skills — the therapy budget — is a target of this power.

The Addendum states that the Bill “includes the ability to specify excluded subgroups of supports within a broader support category”. An ability is not a duty. No subgroup has been excluded.

On the safety duty, the Addendum explains that the requirement “would be supported by advice from the NDIA and the Department”, and that where a determination “is expected to have more than a minor impact”, these matters “would be formalised through an Impact Analysis”. Every verb is conditional. The threshold — more than a minor impact — is assessed by the same executive that wishes to make the determination. None of it appears in the Act. None of it is enforceable by a participant. All of it may be revised, as this Addendum itself demonstrates, by circulating another document.

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I do not say this to be uncharitable. The Addendum is a serious attempt to answer the Committee. It is also, respectfully, the clearest possible demonstration of the point made at the beginning of this submission. Asked to strengthen a safeguard, the Government has strengthened the description of one. The power in subsection 34A stands exactly as it was drafted on 14 May 2026.

If these assurances are sincere — and I have no reason to doubt that they are — the Government should have no objection to enacting them. Put the exclusion of supports essential to health, safety and continuous care into the Act. Put the confinement of categories into the Act. Put the Impact Analysis, and the threshold that triggers it, into the Act. A commitment a government is willing to make in an explanatory memorandum is a commitment it should be willing to make in law. Where it declines, the Committee is entitled to ask why.

I would draw the Committee’s attention to a feature of the explanatory materials that I find difficult to reconcile with the Bill’s own drafting. Those materials acknowledge that broad support reductions carry substantial risks — to safeguarding, to gender equity, to unpaid carers, and to Closing the Gap outcomes. The Government has identified these harms itself. Yet nothing in the Bill obliges anyone to assess that impact independently, to consult before a determination issues, to examine how these harms compound for people who sit at more than one of those intersections, or to go back afterwards and audit what became of the participants whose funding was taken. A power exercised in acknowledged awareness of its risks, with no mechanism to measure whether those risks eventuate, is not a carefully constrained power. It is an unmonitored one.

The Government’s announced use of this power is not hypothetical, and its scale should be stated precisely. It proposes a 50 per cent cut to every Social and Community Participation Supports budget and a 10 per cent cut to every Capacity Building Daily Activities budget. On the Grattan Institute’s analysis, these two cuts alone deliver $13.2 billion of savings over four years — approximately one third of the total NDIS savings in the package — while, in Grattan’s assessment, fixing none of the Scheme’s structural problems. They reduce Scheme growth to 1.1 per cent a year, below inflation. This is a real-terms cut, not a moderation of growth.

As an Occupational Therapist I want to be precise about what the social and community participation category contains. It is not discretionary leisure. It is the funded support that allows a person to leave their home, to attend an appointment, to maintain the community connections that are the single strongest protective factor against the abuse, neglect and exploitation this Parliament examined at length through the Disability Royal Commission. Reducing it is a safety decision, and it is being made without a safety assessment of any individual affected.

The cut is also regressive in its incidence. Grattan’s analysis finds that participants in supported independent living or specialist disability accommodation — among the highest

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need people in the Scheme — hold social and community participation budgets more than five times higher than other participants, and will therefore lose more than five times as much support. These supports comprise more than a quarter of the average plan for participants with intellectual disability, psychosocial disability, Down syndrome, or vision impairment. A uniform percentage cut applied to unequal budgets is not an equal cut. It takes the most from those with the most need.

The interim report records the Agencies’ justification at paragraph 2.126: that absent action, spending on social, civic and community participation is forecast to grow by around $20 billion a year by the end of the decade. Forecast growth in a category of expenditure is a reason to examine why that category is growing. It is not, without more, a reason to reduce every participant’s funding in that category by half, irrespective of whether the individual participant’s use of it is appropriate, clinically indicated, or the only thing standing between them and isolation.

I want to address directly the argument recorded at paragraph 2.129 of the interim report, because I believe it is the most serious error in the Agencies’ evidence. The Agencies advised the Committee that a 50 per cent reduction to a participant’s social, civic and community participation budget ‘might not translate to a 50 per cent reduction in spending, as participants generally do not use their full’ budget; and that for capacity building daily activities a 10 per cent reduction ‘may have an even smaller impact on spending as average utilisation for these supports is around 60 per cent’.

This reasoning does not survive contact with clinical practice. Average utilisation is an average. The participants who exhaust their budgets are not a rounding error in the distribution — they are, systematically, the participants with the highest support needs, the least informal support, and the greatest reliance on funded assistance. A cut calibrated against the mean falls hardest on the tail. Underutilisation is also frequently a symptom of a problem, not evidence of surplus: participants underspend because they cannot find a provider, because they live in a thin market, because they lack the executive function or support coordination to organise services, or because they have been discouraged from claiming. To treat their underspending as headroom for a cut is to penalise people for the barriers the Scheme has failed to remove. It is, in effect, a cut targeted at those who have already been failed.

I also note an unresolved inconsistency within the interim report itself. At paragraph 2.129 the Agencies describe a 50 per cent reduction to social, civic and community participation and a 10 per cent reduction to capacity building daily activities. At paragraph 1.31 of their additional comments, Coalition Senators record that the Minister has indicated the reductions ‘will constitute a 50 per cent reduction to two categories of supports, being the Social Community and Civic Participation and Capacity Building’. Those two statements cannot both be right. Coalition Senators go on to make the point that matters most: the Bill specifies neither figure, and leaves the Minister free to expand reductions to any ’group of

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supports’ by legislative instrument at any time. Parliament is being asked to authorise a power whose announced use it cannot pin down from the face of the legislation.

I welcome the Committee’s finding at paragraph 2.213 that the employment supports line item within the social, civic and community participation budget will not be affected by the 50 per cent reduction, and its call for that protection to be clarified. I would ask the Committee to consider why employment supports warrant that protection and therapy, transport to a medical appointment, or attendance at a community group do not.

3.2 The Capacity Building cut and what it does to therapy

The announced cut to Capacity Building Daily Activities budgets — 10 per cent on the Agencies’ evidence, 50 per cent on the Minister’s reported statement as recorded by Coalition Senators — has attracted a fraction of the attention given to the social and community participation cut. It should not. Capacity Building Daily Activities is the budget line from which allied health supports are funded. It is, in practice, the therapy budget. An across-the-board reduction to it is an across-the-board reduction in therapy, applied without reference to any participant’s clinical need, their therapy goals, or the point they have reached in their intervention. That the Committee cannot presently say whether the figure is 10 per cent or 50 per cent is itself a reason not to grant the power.

I would ask the Committee to notice what a uniform percentage cut does across disciplines. A child receiving weekly speech pathology to establish a communication system, an adult receiving physiotherapy to maintain safe transfers, and a participant receiving occupational therapy to remain in their own home are each reduced by the same proportion, on the same day, for the same reason — which is that none of their circumstances was considered at all.

The reduction will be applied to budgets that are, for some Participants, already implausible. I have clients whose entire capacity building allocation — every therapy, every discipline, every hour of assessment and review — is in the order of $3,000 across a three-year plan. That is not a therapy budget. At standard price limits it purchases a single assessment and a report, once, and nothing further for three years. It is what remains of an entitlement after the difference between a person’s needs and the Scheme’s resolve has been quietly resolved in favour of the second. Reducing such a budget by a further percentage is not a saving. It is the formal abolition of a support that had already ceased to exist in substance.

Capacity building is, by definition, the investment arm of the Scheme. It is the funding that reduces a Participant’s need for paid support later by increasing what they can do for themselves now. Cutting it produces savings in the forward estimates and costs in every year after. If the Committee accepts nothing else in this submission, I would ask it to accept this: an insurance scheme that cuts its capacity-building budget to meet an annual savings target has stopped behaving like an insurance scheme.

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The cut also interacts with proposed subsections 34(1E)–(1F), at proposed subsections 34(1E)–(1F). A practitioner will be required to justify a support against generalised research evidence, and will then have the funded intensity of that support reduced by a Ministerial instrument that has never seen the Participant. Both mechanisms operate on the same supports, in the same direction, at the same time.

There is a further consequence of this cut that I do not think the Committee has been told, and it concerns the protections the Committee believes are in place.

Assistive Technology and Home Modifications are Capital supports. Both were carved out of the support determination power by the amendments announced in June 2026, and the Committee may therefore assume that items such as a Participant’s wheelchair, hoist, shower chair and ramp are safe.

They are not, and the reason is a matter of how the Scheme actually works. A Participant cannot obtain funded assistive technology by asking for it. The item must be assessed, trialled, prescribed and justified by a clinician, in a report that specifies why this equipment, for this person, at this cost. For anything beyond the simplest low-cost item, that clinician is usually an occupational therapist or a physiotherapist. And that assessment is not funded from Capital. It is funded from Capacity Building Daily Activities — the budget line the Government proposes to reduce, and the one nobody has carved out.

So the equipment is protected, and the pathway to the equipment is not. A child may have an untouched Capital allocation and no way to reach it, because the therapy hours that would have produced the prescription have been reduced. The hoist remains fundable in principle. It remains unobtainable in fact. The same is true of the power wheelchair, the pressure-relieving mattress, the bathroom modification, and the communication device.

This is not a technicality. It means the protection the Committee has been offered for Capital supports is, for a substantial number of participants, illusory — and illusory in a way that will not be visible in any dataset, because the claim for the equipment will never be made. There will be no refusal to appeal. There will simply be children who did not get assessed.

If Parliament intends to protect Assistive Technology and Home Modifications, it must also protect the assessments through which they are obtained. A carve-out that shields an item while defunding the clinical work required to prescribe it is not a safeguard. It is the appearance of one.

What this Bill looks like in practice 4.1 What the absence of procedural fairness already looks like

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I want to describe, as plainly as I can, something my practice is seeing now, under the current Act, before any of the provisions in this Bill have commenced. I do so because it indicates how these powers will be exercised once the safeguards are thinner still.

Clients of my practice have received unannounced telephone calls from the Agency, presented as a ‘check-in’. There is no appointment, no notice, and no indication of the call’s purpose. The conversation runs for a matter of minutes. At its conclusion the participant is told that they now have a new plan, and that their funding has been reduced. This has been reported to me not only by my occupational therapy colleagues but by the speech pathologists and physiotherapists in my practice, about the same participants.

These are not planning meetings. The participant has had no opportunity to prepare, to have a support person present, or to gather evidence. No therapy report has been sought. Where reports and recommendations already sit on the participant’s file — assessments I have written, functional evidence, equipment prescriptions — there is no indication that they were read, and no reasons are given that would allow anyone to know whether they were. A participant with cognitive disability, fatigue, or a communication difference is asked, without warning, to represent their own support needs in a few minutes to a stranger. Many of my clients do not understand, when they hang up, what has just happened to them. Some do not tell anyone for weeks.

I want to be careful about the inference I draw. I cannot see the Agency’s internal processes and I do not allege bad faith on the part of individual planners, who are working within systems and targets they did not design. What I can say is what is observable from the outside: a determinative decision, reducing a person’s funded supports, made in a short unscheduled call, without notice, without the participant’s evidence, without apparent regard to the clinical material on file, and without written reasons capable of being tested.

If this is the standard of procedural fairness the Agency achieves while section 31 remains in the Act, while planning decisions are reviewable, and while the reasonable and necessary test still governs, I invite the Committee to consider what it will be once section 31 is repealed, once support determinations and automatic plan renewals are placed beyond review, and once the Minister may reduce a whole category of supports by instrument. The provisions in this Bill do not create this conduct. They remove the remaining grounds on which a participant might contest it.

4.2 The perverse consequence: asking for equipment triggers a cut

A related pattern concerns me more, because of what it teaches Participants.

Participants who seek a plan variation for a specific, clinically justified item of assistive technology — a ceiling hoist, a replacement power wheelchair — have found that the variation process becomes the occasion for a review of their whole plan, and that they emerge with less funding than they began with. The equipment may or may not be approved. The capacity building budget is reduced regardless.

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Consider what this teaches a rational Participant. It teaches them not to ask. A person who needs a hoist, and who has learned that requesting one may cost them their therapy, will go without the hoist. Their carer will continue to lift them manually, and will injure their back, and the cost of that injury will appear in another system. A person who needs a new wheelchair will stay in the failing one until it fails completely. This is not a hypothetical account of behavioural economics. It is what my clients now say to me, in these words: I am not going to ask, because last time they cut my plan.

An insurance scheme in which claiming an entitlement is a risk to your other entitlements has ceased to function as insurance. Proposed section 47A, which expressly contemplates variations that decrease total funding, and which the explanatory materials describe as prepared ‘with the participant’, should be read against this experience. Variations that reduce funding should require a new assessment, the participant’s informed agreement, written reasons, and a right of review.

Human rights and process Australia is a party to the Convention on the Rights of Persons with Disabilities. The Bill engages, at minimum:

Article 4(3) — the obligation to closely consult with and actively involve people with disability in legislation affecting them. A fortnight was initially allowed for submissions on a 109-page Bill accompanied by nearly 300 pages of explanatory material. That is not consultation.
Articles 12 and 17 — legal capacity and the integrity of the person, engaged by conditioning support on submission to treatment.
Article 19 — living independently and being included in the community, engaged directly by reductions to community participation funding.
Articles 25 and 26 — health and habilitation, engaged by caps on therapy intensity determined without reference to individual clinical need.
The principle of non-retrogression: where a State has realised a level of support, it bears a heavy onus to justify moving backwards. Budget savings alone do not discharge that onus.

The Government’s own Statement of Compatibility

Before turning to the Commission’s position, I ask the Committee to read the Statement of Compatibility with Human Rights that accompanies this Bill, prepared under Part 3 of the Human Rights (Parliamentary Scrutiny) Act 2011. It concludes that the Bill “is compatible with the human rights and freedoms recognised or declared” in the listed instruments.

The Statement accepts that the Bill engages Article 19 of the CRPD, the right to live independently and be included in the community, and Article 26, concerning habilitation

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and rehabilitation. Its answer on those articles is this: “The Bill promotes the enjoyment of these rights by improving the quality of providers who deliver plan management services and high risk supports.”

I have read that sentence several times. Article 19 is the right to be included in one’s community. The measure this Bill exists to enable is a 50 per cent reduction in the funding that purchases community participation. The Statement of Compatibility responds to the Article 19 question by describing the regulation of plan management providers. Whatever the merits of that regulation, it is not an answer. A person whose community participation funding is halved is not included in their community because their plan manager is better supervised.

On Article 4(3), the obligation to consult closely with and actively involve people with disability in legislation that concerns them, the Statement observes that the Article “does not require unanimity or agreement from all affected persons”. That is correct as a statement of law. It was also written before the Committee received more than 4,000 submissions and heard three days of evidence in which almost no witness supported the Bill in its current form. Article 4(3) does not require unanimity. It does require that consultation be meaningful, and the distance between a fortnight for submissions on a 109-page Bill and meaningful consultation is not closed by observing that agreement was never required.

I note also that the Supplementary Explanatory Memorandum of 1 July 2026 states that the Government’s amendments “do not impact the Bill’s compatibility with Human Rights”. After the submissions, the hearings, the interim report and the warning of its own NDIS Reform Advisory Committee that the package would cause material harm, the Government’s position on the human rights consequences of this Bill is that nothing has changed.

A Statement of Compatibility is prepared by the Government about its own legislation. That is the design of the scheme, and it is why Parliament established a separate body to examine it. That body has now done so, and its findings should be placed alongside the Government’s.

The Parliamentary Joint Committee on Human Rights

In Report 6 of 2026, the Parliamentary Joint Committee on Human Rights — a multi-party committee established under the Human Rights (Parliamentary Scrutiny) Act 2011 — examined this Bill across fifty-seven pages. It did not conclude that the Bill is compatible with human rights. It concluded, repeatedly, that the Bill may limit them, and it has sought the Minister’s advice on matters that remain unresolved.

On the financial sustainability measures, the Committee found that embedding financial sustainability in the Act “may result in fewer supports being approved and less funding being provided to participants, which may have an adverse impact on participants’

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independence and quality of life”, and that this “would engage and may limit the rights of persons with disability, and the rights to an adequate standard of living and health”.

On children, the Committee found that because it is not clear the best interests of the child would be a primary consideration in working out a total funding amount or in matters relating to assessments, the measures “would engage and may limit the rights of the child”. That finding should be read alongside the presumption of parental responsibility in proposed subsections 34(1G)–(1J), and alongside the fact that two in three new participants are under fifteen.

Most significantly, the Committee addressed the doctrine of non-retrogression. It observed that “under international human rights law, the introduction of retrogressive measures should be accompanied by evidence that such measures are temporary, necessary and non discriminatory and that they respect the state’s core obligations in relation to the rights of people with disability”. Its conclusion was unambiguous: “The committee considers that it has not been demonstrated that these requirements have been met.”

The Committee further found it “unclear whether the measures pursue the legitimate objective of promoting the general welfare, noting the measures may have disproportionate impacts on a vulnerable group”, and that it was not possible to assess the adequacy and availability of alternative health and disability supports. On proportionality, it considered it “unclear how the measures will operate in practice and, noting the significant extent of the interference with rights that may result from the measures, what safeguards may be available”. It drew these overarching concerns to the attention of the Minister and the Parliament.

I ask this Committee to hold three documents side by side. The Government’s Statement of Compatibility asserts that the Bill “is compatible with the human rights and freedoms” recognised in the listed instruments. The Parliamentary Joint Committee on Human Rights finds that the Bill may limit the rights of people with disability, the rights to an adequate standard of living and health, and the rights of the child, and that the Government has not demonstrated the conditions under which a retrogressive measure may lawfully be introduced. And the Supplementary Explanatory Memorandum of 1 July 2026 certifies that the Government’s amendments “do not impact the Bill’s compatibility with Human Rights”.

The scrutiny mechanism Parliament built for exactly this situation has done its work and reported serious, unresolved concerns. The Minister has been asked for advice. Until that advice is given, considered, and the Parliamentary Joint Committee on Human Rights is in a position to complete its assessment, this Bill should not be voted upon. To proceed now would be to legislate a retrogressive measure that the Parliament’s own human rights committee has said has not been shown to meet the conditions international law requires of it.

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I endorse the Australian Human Rights Commission’s position that the Bill should not pass before the Parliamentary Joint Committee on Human Rights has assessed the Statement of Compatibility, a comprehensive gender impact analysis is completed, and the disability community is genuinely involved in the reform. Disability Discrimination Commissioner Rosemary Kayess has said the Bill has the potential to be regressive in the protection and realisation of the rights of people with disability. I share that assessment.

I would draw the Committee’s attention to the breadth of the opposition already on its own record. Australia’s Disability Representative Organisations have jointly recommended the Bill not proceed in its current form or within the current timeframe. The Government’s own NDIS Reform Advisory Committee has warned the package would cause material harm. The States and Territories told the Committee they have made no agreement to deliver like-for like services to people exited from the Scheme. The Grattan Institute — which supports structural NDIS reform and says a reform bill needs to pass — describes the immediate cuts as brutal and calls for their removal. The Australian Greens recommend the Bill be withdrawn, and that no participant be removed from the Scheme until foundational supports are fully implemented, evaluated and proven to meet the needs of those who will rely on them. I support that second proposition without reservation, whatever the fate of the first.

This is not a sector resisting change. It is a sector, including its most reform-minded voices and the Government’s own advisory body, telling Parliament that these particular measures will cause harm.

I would add one further condition, and it is the one that matters most. The Government’s own reform architecture assumes that people leaving or excluded from the Scheme will be supported by foundational supports funded jointly with the States and Territories. Those supports do not yet exist in any developed form in Western Australia. Legislating the exit before building the destination will leave people with disability with neither. No participant should be removed from the Scheme, and no eligibility narrowing should commence, until foundational supports are operational, independently evaluated, and demonstrated to be adequate.

Conclusion The Bill is titled ‘Securing the NDIS for Future Generations’. I would ask the Committee to test that title against the Bill’s own text. A Scheme in which a Minister may reduce assessed supports by instrument, cap the intensity of therapy without seeing the person receiving it, set the prices at which supports are delivered while holding the Budget line for them, override the Act by rule for twelve months, and remove existing participants against a threshold measured by a tool not yet designed — that is not a secured Scheme. It is a Scheme in which entitlement has been replaced by discretion.

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The scale of what is proposed is on the record. In their dissenting report, the Australian Greens state that the Government’s own modelling shows 241,000 people will be removed from the Scheme by 2031 as a result of reassessment and the stricter eligibility conditions. In their additional comments, Senator Pocock and others record the same concern. The interim report itself records the States’ and Territories’ warning that ‘significant projected participant exits by 2031 are not accompanied by clearly defined alternative supports’, that they are ‘not in a position, and have made no agreement, to deliver like-for-like services to people who are exited from the NDIS’, and that people ‘will end up in hospitals or other settings that are inappropriate and can’t meet their needs or with no services at all’.

Those alternative supports, in Western Australia, do not yet exist in any form to which I can refer a client. I would ask each member of the Committee to hold those two facts together: a quarter of a million people are to leave the Scheme, and the systems meant to receive them say they cannot.

Every clinician who works in the NDIS has watched a Participant’s functional capacity improve because the right support was delivered at the right intensity at the right time. That happens because someone assessed the person, exercised professional judgement, and was funded to act on it. This Bill removes each of those three things. What it will save in the forward estimates it will spend, many times over, in hospital admissions, in crisis accommodation, in the health of carers, and in the preventable loss of capacity that this Scheme was created to prevent.

I ask the Committee to recommend against the Bill proceeding in its current form.

Sources

Senate Community Affairs Legislation Committee, National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026, Interim Report, June 2026 — including the Agencies’ evidence at paragraphs 2.126 and 2.129, the Committee’s findings at 2.213–2.214, Recommendations 1–4, Coalition Senators’ additional comments, and the Australian Greens’ dissenting report.
Justice and Equity Centre, Explainer: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026, 21 May 2026.
Australian Human Rights Commission, Submission to the Community Affairs

Legislation Committee, 28 May 2026. Parliamentary Joint Committee on Human

Rights, Report 6 of 2026, concerning this Bill.

Australia’s Disability Representative Organisations, Joint Submission to the Community Affairs Legislation Committee, 1 June 2026.
S Bennett, ‘Brutal NDIS cuts will hurt the most vulnerable’, Grattan Institute / The Australian, 9 June 2026.

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Occupational Therapy Society for Hidden and Invisible Disabilities (OTSi), Submission 32 to this inquiry, 21 May 2026.
Independent Review into the NDIS, Working together to deliver the NDIS: Final Report and Supporting Analysis, December 2023.
Public hearings of the Committee, Melbourne 9 June and Canberra 10–11 June 2026.
Australian Greens, ‘Greens secure longer inquiry into NDIS’, media release, 23 June 2026 (schedule of agreed amendments).
Explanatory Memorandum to the Bill; NDIA v Davis [2022] FCA 1002; NDIA v Sutherland [2026] FCA 3; CEO of the NDIA v Eastham [2026] FCA 147; McGarrigle v NDIA [2017] FCA 308.

Juliana Wilks

Occupational Therapist/Director

Spectrum Therapy WA

10 July 2026

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