Concerns regarding workforce impact assessment for pricing determinations (Provider advocacy)

Submission 2530

Submission to the Senate Community Affairs​

Legislation Committee

Inquiry into the National Disability Insurance Scheme Amendment​

(Securing the NDIS for Future Generations) Bill 2026

Submitted by Support Worker Association of Australia

Submitted by Carly Nisner, Founder

Website supportworkerassociation.org Contact hello@swaa.au

Address 4 Ida Street, Charlestown NSW

The Support Worker Association of Australia

Publication

consents to this submission being published. Date 10 July 2026

Securing the NDIS requires securing​ the human workforce that delivers it.

Submission 2530

Contents

Main sections

1. Executive summary 4
2. Recommendations 5

Recommendations

Recommendation 1 - Do not proceed in the Bill’s current 5 form Recommendation 2 - No reductions before alternative 5 supports are real and available Recommendation 3 - No blanket reductions without 6 individual risk assessment Recommendation 4 - Preserve urgent plan variation and 6 reassessment pathways Recommendation 5 - Allow support workers and providers to 6 contribute information with participant consent Recommendation 6 - Strengthen safeguards before plan 6 suspension or participant status revocation Recommendation 7 - Make provider registration and 7 enrolment risk-proportionate Recommendation 8 - Support ethical workers and providers 7 to comply before penalising them Recommendation 9 - Require workforce impact assessment 7 for pricing determinations Recommendation 10 - Protect participant choice and continuity in plan management and support coordination 7 reforms Recommendation 11 - Require human accountability for automation and contextual safeguards for 8 functional-capacity assessment Recommendation 12 - Establish a Support Worker Reform 8

Advisory Group

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Remaining sections

3. About the Support Worker Association of Australia 8

4. Consultation note 9

5. Scope of this submission 9

6. SWAA’s position on the amended Bill 10

7. Social and community participation is not an optional 11 extra

8. Unscheduled reassessments and urgent plan changes 12 must work in real life

9. Plan suspension and participant status revocation must 12 not punish people for being hard to reach

10. Regulation must improve safety without pushing ethical 13 workers and small providers out

11. Record keeping, claiming and payment reforms must 14 support compliance, not create fear

12. Pricing is a participant safety issue, not only a budget 15 issue

13. Plan management and support coordination reforms 15 must protect choice, continuity and local knowledge

14. Functional capacity assessment must not become 16 disconnected from real life

15. Automated administration must include human 17 accountability

16. Implementation must include support workers 17

17. Practical illustrations of foreseeable impact 18 Reduced community participation 18 Urgent reassessment not activated early enough 18 Plan suspension risk where contact fails 18 Sole trader exits because compliance becomes too 18 complex Pricing affects safety and continuity 18

18. Conclusion and request to appear 19 References 19

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1. Executive summary The Support Worker Association of Australia welcomes the opportunity to provide this submission to

the Senate Community Affairs Legislation Committee’s inquiry into the National Disability Insurance

Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

SWAA has considered the Bill, the third reading version of the Bill after it passed the House of Representatives on 2 July 2026, and the amendments agreed in the House of Representatives on 1 July 2026. The third reading Bill states that the Bill originated in the House of Representatives, had passed that House and was ready for presentation to the Senate for concurrence on 2 July 2026. [2] The Department of Health, Disability and Ageing states that key amendments were moved and agreed in the House on 1 July 2026. [6]

SWAA understands that the Bill seeks to amend the National Disability Insurance Scheme Act 2013 and related legislation across significant areas including access and planning, functional capacity, plan reassessment, reasonable and necessary supports, provider regulation, fraud and compliance, record keeping, claims timeframes, plan management, pricing, automated administrative action, new framework planning and transitional arrangements. The Parliamentary Library Bills Digest describes the Bill as aimed at reducing projected growth in NDIS expenditure and participant numbers while strengthening fraud controls, provider regulation and governance arrangements. [3]

SWAA welcomes amendments where they improve clarity, transparency and safeguards. However, SWAA remains concerned that the Bill, even as amended, does not yet contain sufficient protections for participants, support workers, ethical providers, thin markets, or the continuity of high-quality human support.

SWAA supports a sustainable, safe and high-integrity NDIS. We support measures that strengthen safeguarding, reduce fraud, improve quality, and protect the Scheme for future generations. However, SWAA does not support the Bill proceeding in its current form.

SWAA is a national association representing and supporting Australia’s support workers, including employees, independent support workers, sole traders, and businesses and providers who employ support workers. SWAA makes this submission from a support worker and industry leadership lens, with a strong focus on participant rights, participant safety, support worker wellbeing, ethical provider sustainability, and the future of high-quality disability support in Australia.

SWAA does not seek to replace or speak over participant voice. Participant voice, lived experience, choice and control must remain central to NDIS reform. SWAA’s contribution is different and complementary: we bring the perspective of the support worker workforce and the practical realities of turning NDIS plans into real support.

Support work is skilled work. Support work is human work. This is not only SWAA’s position. It is reflected in the NDIS Workforce Capability Framework, which the NDIS Quality and Safeguards Commission describes as setting out the attitudes, skills and knowledge expected of all workers funded under the NDIS. [7]

A plan does not support someone by itself. Support workers bring plans to life. They assist people to participate in their communities, maintain routines, build skills, stay connected, manage risk, communicate needs, access appointments, sustain relationships, and live with greater independence and dignity.

The NDIS cannot be secured by making community life smaller, making good workers fearful, narrowing participant choice, or placing more administrative burden on ethical providers without practical support.

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SWAA is particularly concerned about the potential impact of the Bill and associated implementation settings on participant access to social, civic and community participation; support worker employment, continuity and wellbeing; sole traders, independent workers and small ethical providers; participants who need urgent plan changes; people who may be difficult for the NDIA to contact; rural, regional and thin-market communities; pricing settings; administrative and compliance changes; automation; and reforms that rely on future foundational supports or future review mechanisms rather than enforceable safeguards before implementation.

SWAA does not dispute that the NDIS must be sustainable. A Scheme that cannot be sustained cannot protect participants now or in the future. However, sustainability cannot be measured only through short-term reductions in plan spending. True sustainability requires preventing crisis, maintaining community inclusion, supporting ethical providers, retaining skilled workers, reducing avoidable hospitalisation and family breakdown, and ensuring participants can access the supports that keep them safe and connected.

The Department’s participant and provider guidance states that from 1 October 2026, budget allocations for social, civic and community participation supports will be reduced by 50 per cent, and capacity building daily activity budget allocations will be reduced by 10 per cent, progressively as plans are renewed or reassessed over a 12-month period. [5] SWAA considers this one of the most significant participant and workforce issues connected with the Bill.

SWAA’s position is simple: no cuts before alternatives, no reform without participants, and no implementation without support workers.

SWAA recommends that the Bill not proceed in its current form. At minimum, it should be amended to include enforceable safeguards for participants, support workers, ethical providers, thin markets and the continuity of high-quality human support.

2. Recommendations SWAA recommends that the Senate Community Affairs Legislation Committee make the following recommendations.

SWAA has framed these recommendations as practical amendments, commencement safeguards and implementation requirements that would allow the objectives of sustainability, safeguarding and integrity to be pursued without avoidable harm to participants, support workers and ethical providers.

Recommendation 1 - Do not proceed in the Bill’s current form

SWAA recommends that the Committee recommend that the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 not proceed in its current form.

The Bill should be amended to include stronger and enforceable safeguards for participants, support workers, ethical providers, thin markets, and the continuity of high-quality human support.

SWAA supports sustainability, safeguarding and integrity. However, sustainability must be achieved in a way that protects participant safety, community inclusion, workforce stability, provider viability and choice and control.

Recommendation 2 - No reductions before alternative supports are real and available

SWAA recommends that reductions to social, civic and community participation supports and capacity building daily activity supports not commence in a participant’s local area unless and until alternative

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supports are operational, fully funded, accessible, locally available, disability-informed, culturally safe, co-designed with people with disability, safe for participants with complex support needs, and independently assessed as capable of safely replacing or supplementing reduced NDIS supports.

A participant cannot be safely transitioned to a support that does not exist. This should operate as a commencement safeguard, not only a policy aspiration.

Recommendation 3 - No blanket reductions without individual risk assessment

SWAA recommends that any reduction to social, civic and community participation supports or capacity building daily activity supports require an individual assessment of participant goals, disability-related need, safety risk, social isolation risk, informal support availability, family and carer sustainability, rural, regional or thin-market barriers, availability of safe and suitable alternatives, likely impact on wellbeing, inclusion and capacity, and likely impact on continuity of trusted support relationships.

Social and community participation should not be reduced through a blunt percentage mechanism that does not properly consider individual circumstances.

Recommendation 4 - Preserve urgent plan variation and reassessment pathways

SWAA recommends that the Bill and associated implementation rules preserve a fast, accessible and practical pathway for urgent plan variations and reassessments, including where there is carer breakdown, provider withdrawal, family violence, housing instability, hospital discharge, psychosocial crisis, sudden deterioration in functional capacity, loss of informal supports, worker safety concerns, increased behaviour support needs, or rural or thin-market service failure.

SWAA acknowledges that departmental guidance states participants in crisis or emergency situations may request a plan variation. However, the pathway must be clearly defined, accessible, timely and widely communicated to participants, families, support workers, providers and advocates. [5]

Recommendation 5 - Allow support workers and providers to contribute information with participant consent

SWAA recommends that, with participant consent, authorised support workers, providers, allied health professionals, advocates and support coordinators be able to contribute information relevant to urgent plan variations and reassessments.

Support workers should not make decisions for participants. However, support workers are often the people who see early changes in participant wellbeing, safety, routine, communication, function, distress, risk and informal support breakdown. Their evidence should not replace participant voice, but it should be able to inform decision-making where the participant wants that information included.

Recommendation 6 - Strengthen safeguards before plan suspension or participant status revocation

SWAA recommends that no participant’s plan be suspended and no participant status be revoked unless the NDIA has undertaken active, accessible and trauma-informed outreach.

SWAA acknowledges that Government amendments strengthen minimum requirements for reasonable attempts to contact a participant before plan suspension or participant status revocation, including direct contact with the participant, nominee or authorised person, at least five attempts through the person’s preferred means of contact, and attempts over a three to four month period. The amendment also provides that attempts do not count if the participant is in hospital, an institution or experiencing homelessness. [6]

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These amendments are welcome, but they are not sufficient by themselves. Safeguards should also explicitly consider family violence, coercive control, psychosocial crisis, cognitive disability, acquired brain injury, communication disability, language barriers, digital exclusion, poverty, unstable phone or internet access, loss of informal supports, rural or remote isolation, and unsafe housing or unstable accommodation that may not meet a narrow definition of homelessness.

No participant should lose access to the NDIS because the system could not reach them safely. Suspension should be a last resort, not an administrative shortcut.

Recommendation 7 - Make provider registration and enrolment risk-proportionate

SWAA recommends that provider registration and enrolment reforms be risk-proportionate, staged, low-cost and co-designed with support workers, sole traders, small providers, participants and families.

Regulation should match the nature of the support, level of risk, setting, participant circumstances, worker role, provider size and structure, thin-market conditions, and rural and remote access issues.

A sole trader providing community access support should not face the same regulatory burden as a large provider delivering complex shared living support. Risk-proportionate regulation is the pathway to better safety without reducing participant choice or pushing ethical workers out of the sector.

Recommendation 8 - Support ethical workers and providers to comply before penalising them

SWAA recommends that record-keeping, claiming and payment reforms be supported by practical implementation measures before penalties are relied on. These measures should include plain-English guidance, templates, simple digital tools, education before penalties, transition periods, reasonable timeframes for small providers to adapt, clear distinctions between fraud and genuine administrative error, accessible support for sole traders and independent workers, and proportional treatment of minor or unintentional mistakes.

SWAA supports strong action against fraud and exploitation. However, ethical workers and small providers should not be placed in fear of disproportionate civil penalties for minor or unintentional administrative mistakes, particularly during transition to new systems.

Recommendation 9 - Require workforce impact assessment for pricing determinations

SWAA recommends that any Ministerial pricing determination be accompanied by a published workforce impact assessment.

That assessment should consider fair wages, worker supervision, training and induction, travel and transport realities, administrative and documentation time, cancellations and roster instability, worker safety, rural and remote delivery, participant complexity, culturally safe support, trauma-informed practice, provider viability, continuity of participant support relationships, and the effect of pricing on sole traders, small providers and thin markets.

Pricing is not just a budget tool. Pricing determines whether support work is viable, skilled, safe and sustainable.

Recommendation 10 - Protect participant choice and continuity in plan management and support coordination reforms

SWAA recommends that plan management and support coordination commissioning reforms include enforceable protections for participant choice, continuity of trusted relationships, local knowledge, specialist expertise, rural and thin-market access, culturally safe providers, small and specialised

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providers, transparent selection criteria, conflict-of-interest safeguards, clear complaints and review pathways, and staged transition for participants and providers.

SWAA acknowledges the need to improve quality, integrity and conflict-of-interest safeguards. However, commissioning and panel arrangements must not narrow participant choice, disrupt trusted relationships, or unintentionally favour larger providers over smaller, local and specialised providers.

Recommendation 11 - Require human accountability for automation and contextual safeguards for functional-capacity assessment

SWAA recommends that any automated administrative process used by the NDIA include human oversight, clear reasons for decisions, accessible communication, easy review pathways, payment safeguards, protections for participants who cannot use digital systems, protections for workers and providers affected by incorrect data or delayed payments, and published information about what the automated process does and does not decide.

SWAA also recommends that functional-capacity assessment under the Bill be designed and implemented so that it does not become disconnected from real-life support need, risk and sustainability. Proposed section 9B defines functional capacity in relation to an activity as a person’s ability to undertake that activity without assistance from other people, assistive technology or modifications, and in a context that excludes, as far as possible, the impact of the person’s environmental and personal circumstances. [2]

SWAA’s concern is that if this assessment framework is not carefully designed and implemented, it may produce decisions that appear consistent on paper but fail to reflect real-life support need, risk and sustainability.

Recommendation 12 - Establish a Support Worker Reform Advisory Group

SWAA recommends that the Australian Government establish a formal Support Worker Reform Advisory Group to inform implementation of this Bill and related NDIS reforms.

SWAA does not recommend a support worker advisory mechanism for the benefit of any single organisation. We recommend it because implementation will fail if the workforce expected to deliver the reforms is not included in their design.

The group should include employee support workers, independent support workers, sole traders, small providers, rural and remote support workers, workers supporting participants with complex needs, workers with lived experience of disability, culturally and linguistically diverse workers, First Nations workers, providers who employ support workers, and participant and family representatives.

Nothing for us without us must include participants. It must also include the support workers who stand beside them every day.

The following sections explain the practical basis for SWAA’s recommendations. They focus on the areas of the Bill and associated implementation settings most likely to affect participants, support workers, sole traders, small providers, ethical providers and thin markets.

3. About the Support Worker Association of Australia The Support Worker Association of Australia is a national association representing and supporting Australia’s support workers.

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SWAA represents employees, independent support workers, sole traders, and businesses and providers who employ support workers. SWAA has more than 400 members and a broader national community of more than 4,000 people across social media, online groups and email networks.

SWAA exists to recognise, strengthen and support the support worker workforce. Our work is grounded in a simple belief: support work is skilled work, and support work is human work.

Support workers are not peripheral to the NDIS. They are central to whether the Scheme works in real life.

A plan does not support someone by itself. Support workers help turn plans into safety, inclusion, community participation, routines, skill development, communication, dignity and ordinary life. They are often the people who notice changes in a participant’s wellbeing, function, communication, behaviour, safety, carer stress, social isolation, housing stability and support needs.

SWAA makes this submission from a support worker and industry leadership lens, with a strong focus on participant rights, participant safety, choice and control, support worker wellbeing, support worker dignity and professional recognition, ethical provider sustainability, fraud prevention without punishing ethical workers and providers, thin markets and rural access, and the future of high-quality disability support in Australia.

SWAA does not seek to replace or speak over participant voice. Participant voice, lived experience, choice and control must remain central to NDIS reform. SWAA’s contribution is different and complementary. We bring the perspective of the support worker workforce and the practical realities of turning NDIS plans into real support.

The NDIS cannot be secured without securing the human workforce that delivers it.

4. Consultation note Due to the timeframe for this inquiry, SWAA has not undertaken a formal consultation process specifically for this submission.

This is an organisational submission by SWAA leadership. It draws on SWAA’s national role representing and supporting Australia’s support workers, including employees, independent workers, sole traders and providers who employ support workers.

Although this submission is not presented as a formal member consultation, SWAA’s position is informed by ongoing engagement with the support worker ecosystem. This includes contact with members, independent workers, sole traders, employees, providers, 1:1 mentoring, community discussion, sector education, online groups, social media engagement, direct industry contact and SWAA’s broader work supporting the disability support workforce.

These channels are not presented as a formal survey, statistical sample or representative consultation process. They are included to explain the practical foundation of SWAA’s organisational understanding of the support worker workforce and the real-world conditions in which NDIS support is delivered.

5. Scope of this submission The Committee has stated that it will only accept submissions that directly address the provisions of the Bill, and that personal experiences relating to the NDIS or the NDIS Quality and Safeguards Commission must specifically address aspects of the Bill. [1]

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SWAA’s submission addresses the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 as amended, and the practical reforms enabled, supported or directly connected to the Bill.

This submission focuses on provisions and implementation settings relating to access and planning; functional capacity; plan reassessment; support funding reductions; plan suspension and participant status revocation; reasonable and necessary supports; provider regulation; provider enrolment; record keeping; claiming; plan management; pricing; automated administrative action; implementation safeguards; and support worker workforce impacts.

Where this submission refers to implementation dates, public guidance or Departmental explanation, SWAA does so because those materials explain how the Bill and associated NDIS reform package are intended to operate in practice.

SWAA’s focus is the real-world impact of the Bill and associated implementation settings on participants, support workers, sole traders, small providers, ethical providers, rural and regional communities, and thin markets.

6. SWAA’s position on the amended Bill SWAA supports a sustainable, safe and high-integrity NDIS. We support measures that strengthen safeguarding, reduce fraud, improve quality, and protect the NDIS for future generations. However, SWAA does not support the Bill proceeding in its current form.

SWAA acknowledges the amendments agreed in the House of Representatives on 1 July 2026. Amendments that improve clarity, transparency and safeguards are welcome. However, SWAA remains concerned that the Bill, even as amended, does not yet contain sufficient protections for participants, support workers, ethical providers, thin markets, or the continuity of high-quality human support.

The amendments are a start, but they are not enough.

SWAA’s concern is that the Bill still places too much reliance on future consultation, future foundational supports, future implementation decisions, future market adjustment and future review mechanisms. Participants, support workers and ethical providers may experience the practical impacts of these reforms much sooner.

The amended Bill includes a 2029 independent review. The Department’s amendments material states that the review must examine matters including access to the NDIS, participant outcomes, continuity and quality of supports, review and appeal rights, provider market viability and sustainability, service delivery in thin markets, and interaction with foundational supports or related support systems. [6] SWAA supports independent review. However, a review after implementation is not a substitute for safeguards before implementation.

SWAA does not dispute that the NDIS must be sustainable. A Scheme that cannot be sustained cannot protect participants now or in the future. However, sustainability cannot be measured only through short-term reductions in plan spending.

SWAA is not asking Parliament to choose between sustainability and people. SWAA is not asking Parliament to slow reform for the sake of delay. SWAA is asking Parliament to build safeguards into reform so that sustainability is achieved without preventable harm.

A system that reduces preventative community support may save money on paper while increasing isolation, crisis and informal carer pressure in real life. A system that increases regulation without practical support may reduce fraud while also pushing ethical sole traders and small providers out of

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thin markets. A system that sets prices without workforce impact assessment may control costs while weakening the workforce needed to deliver safe support. A system that automates administration without human accountability may increase efficiency while creating harm that participants, workers and providers have to untangle.

That is why SWAA’s position is clear: no cuts before alternatives, no reform without participants, and no implementation without support workers.

7. Social and community participation is not an optional extra SWAA is deeply concerned about the Bill’s proposed mechanism for reducing funding for specified groups of supports, and the Government’s stated intention to use this mechanism to reduce social, civic and community participation supports and capacity building daily activity supports.

The Parliamentary Library Bills Digest identifies that the Bill introduces a power for the Minister to reduce funding for specified groups of supports. [3] Departmental guidance states that from 1 October 2026, budget allocations for social, civic and community participation supports will be reduced by 50 per cent, and capacity building daily activity budget allocations will be reduced by 10 per cent. These changes will happen progressively as participants’ plans are renewed or reassessed over a 12-month period. [5]

SWAA understands the need for Scheme sustainability. However, social and community participation should not be treated as a soft target or optional extra.

For many participants, community participation is where safety, confidence, communication, routine, skills, relationships and belonging are built. It is often the support that enables a person to be seen, known, connected and included outside their home.

In practical terms, social and community participation support may assist a participant to leave the house safely, attend ordinary community activities, develop social confidence, maintain routine, build capacity, reduce isolation, access exercise or volunteering, communicate choices in real environments, maintain relationships beyond family or paid services, and reduce risk of crisis escalation.

This is not a luxury. It is often preventative support.

A participant who loses community access may not only lose an activity. They may lose structure, connection, visibility, routine and early identification of risk. Families and informal carers may be expected to absorb the gap. Support workers may lose hours, continuity and employment security. Small providers may lose the predictable work that allows them to remain viable in local communities.

The Department’s guidance states that the NDIS was built on the promise of inclusion and to give people with disability real opportunities for connection and capacity development. It also states that the Government will provide $200 million for an Inclusive Communities Fund, with consultation on that fund starting in July 2026. [5] SWAA welcomes investment in inclusive communities. However, an Inclusive Communities Fund is not, by itself, a safe replacement for individualised support.

Community programs are valuable, but they do not automatically replace disability-related support needs, skilled support relationships, transport, communication support, personal care, behavioural support, psychosocial support, risk management or one-to-one support required for safe participation.

No reduction to social, civic and community participation or capacity building daily activity supports should commence unless alternative supports are real, funded, accessible, disability-informed, locally available, culturally safe, co-designed with people with disability, and independently assessed as safe.

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A participant cannot be safely transitioned to a support that does not exist.

8. Unscheduled reassessments and urgent plan changes must work in real life

SWAA is concerned that the Bill and associated reforms may make it harder for participants to access timely plan changes when their support needs change quickly.

The Bills Digest identifies that the Bill amends access and planning arrangements, including by limiting participant-requested plan reassessments. [3] Departmental guidance states that only participants, their plan nominee or their guardian will be able to request an unscheduled plan reassessment, that unscheduled reassessments will only be possible in specified circumstances, and that the NDIA will have up to 90 days to decide whether to vary or reassess a plan. [5]

SWAA acknowledges that departmental guidance also states that where a participant has experienced fraud, or is in a crisis or emergency situation, they can request a plan variation. [5] That safeguard is welcome. However, a safeguard that exists on paper will not prevent harm if participants, families, support workers, providers and advocates do not know how to activate it, or if the criteria are applied too narrowly.

Support needs do not always change neatly, slowly or predictably. Urgent changes may arise because of carer breakdown, family violence, loss of housing, hospital discharge, provider withdrawal, sudden deterioration in functional capacity, psychosocial crisis, increased behaviour support needs, worker safety risk, sudden loss of informal support, rural or thin-market service failure, breakdown of a support relationship, or loss of transport, communication or community access.

A participant in one of these situations may not have the capacity, confidence or support to request a reassessment or variation quickly. A participant experiencing crisis may not describe their needs in the language the system expects. A person experiencing family violence, coercive control, psychosocial distress, cognitive disability or communication barriers may not be able to navigate the process at all without assistance.

Support workers are often the first people to notice when things are changing. They may notice missed meals, cancelled appointments, withdrawal from community, reduced personal care, escalation of distress, or increasing reliance on informal supports that are close to breaking down.

Support workers should not make decisions for participants. They should not replace participant voice. But with participant consent, they should be able to contribute relevant information where they have observed changes in safety, function, communication, wellbeing, informal support, risk or service availability.

A 90-day decision period may be appropriate for some administrative matters. It is not appropriate where the issue is urgent, escalating or safety-related. The system should be designed to respond before crisis becomes harm.

9. Plan suspension and participant status revocation must not punish people for being hard to reach

SWAA remains concerned about provisions relating to plan suspension and participant status revocation where the NDIA is unable to contact a participant.

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The Bills Digest identifies that the Bill expands the circumstances in which a person’s plan can be suspended. [3] SWAA acknowledges that amendments have been made to strengthen contact-attempt safeguards. Departmental amendments material states that before a participant’s plan is suspended or their status is revoked, the NDIA must contact the participant, nominee or authorised person directly, make at least five attempts through the person’s preferred means of contact, and ensure the first and last attempt are between three and four months apart. It also states that attempts do not count if the participant is in hospital, an institution or experiencing homelessness. [6]

These amendments are welcome. They are also incomplete.

The Committee should consider who is most likely to be difficult for the NDIA to contact. It may be people experiencing psychosocial crisis, cognitive disability, acquired brain injury, intellectual disability, communication disability, homelessness, unstable housing, family violence, coercive control, poverty, phone disconnection, digital exclusion, language barriers, rural or remote isolation, hospitalisation, incarceration, loss of informal support, or distrust of government systems because of trauma.

These are not people who should be pushed further away from support. They are often people who need stronger safeguards.

A participant may technically have a preferred contact method recorded, but that method may no longer be safe, available, accessible or monitored. A participant fleeing family violence may have changed phone numbers. A participant in psychosocial crisis may not open mail or answer calls. A person with cognitive disability may not understand the significance of a letter. A person in unstable housing may not receive post.

No participant should lose access to the NDIS because the system could not reach them safely.

Before any plan suspension or participant status revocation occurs, the NDIA should be required to undertake active, accessible and trauma-informed outreach, including checking whether the participant’s preferred contact method is still safe and active, contacting a nominee or authorised representative, contacting a known advocate where appropriate, considering family violence or communication barriers, using accessible formats and plain-English communication, and providing a clear reinstatement pathway where contact is restored.

Suspension should be a last resort, not an administrative shortcut. A system that loses people because they are hard to contact is not a safe system.

10. Regulation must improve safety without pushing ethical workers and small providers out

SWAA supports stronger safeguarding, provider oversight, fraud prevention and action against exploitation. Ethical support workers and providers want poor practice addressed because it harms participants, damages trust and undermines the sector.

SWAA’s concern is not regulation itself. SWAA’s concern is regulation that is not risk-proportionate, not clearly communicated, not supported by education, and not designed for the realities of sole traders, independent workers, small providers and thin markets.

The Bills Digest identifies that the Bill strengthens fraud, compliance and regulatory arrangements, including by changing the definition of NDIS provider, introducing civil penalties, expanding information-gathering powers, imposing record-keeping requirements, changing claims timeframes and amending plan management arrangements. [3]

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Departmental guidance states that mandatory registration will be expanded to providers delivering higher-risk supports, with expanded registration requirements beginning to roll out from 1 July 2027 and all in-scope providers required to be registered by December 2030. The same guidance states that most providers will need to enrol with the NDIA from 1 July 2027 so payments can be made into a nominated and validated bank account. [5]

SWAA supports the principle that higher-risk supports require stronger oversight. Participants should be able to trust that providers delivering higher-risk supports are safe, competent and accountable. However, the design matters.

A sole trader providing community access support is not the same as a large provider delivering complex shared living supports. A small rural provider is not in the same position as a large metropolitan organisation with compliance staff, legal support, HR systems and administrative teams. An independent support worker may be highly skilled and ethical, but still struggle with complex systems, unclear rules and unpaid administrative burden.

Poorly designed regulation may produce unintended consequences: ethical sole traders may exit the sector, small providers may decide the compliance burden is no longer viable, rural and regional participants may lose local options, participants may have fewer choices, thin markets may become thinner, larger providers may be favoured by default, workers may become fearful rather than supported, and administrative compliance may crowd out quality practice.

Regulation should lift quality, not remove good people from the sector. The NDIS needs strong safeguards. It also needs enough skilled, ethical workers and providers to deliver support. Both things must be true.

11. Record keeping, claiming and payment reforms must support compliance, not create fear

SWAA supports appropriate record keeping, transparent claiming and action against fraud. Good records protect participants, workers and providers. Clear records can improve safety, accountability, continuity and payment integrity.

However, record keeping and claiming systems must be practical for the people expected to use them.

Departmental guidance states that providers will need to keep records relating to payment and receipt of NDIS funds for seven years, that failure to retain records will result in a civil penalty, and that from 1 December 2026 the time to make a claim for supports under a participant’s plan will be reduced from two years to 90 days. [5]

SWAA’s concern is that these changes may be experienced by ethical workers and small providers as fear-based compliance unless they are implemented carefully.

Many sole traders and small providers do not have compliance departments. Many independent workers complete documentation after hours. Some workers are highly skilled in direct support but have had limited training in business systems, compliance documentation or regulatory administration. This does not mean standards should be lowered. It means the system should support people to meet them.

There must be a clear distinction between deliberate fraud, exploitation, reckless non-compliance, poor practice, misunderstanding, system error, late payment processes, plan management delays, minor administrative mistakes and genuine transition issues.

A system that treats every administrative error as suspicious will not build integrity. It will build fear.

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SWAA recommends an education-before-penalties approach for ethical workers and providers, especially during transition to new systems. The goal should be simple: make it easier for good workers and providers to do the right thing, and harder for bad actors to exploit the Scheme.

12. Pricing is a participant safety issue, not only a budget issue SWAA considers pricing one of the most important workforce issues connected to the Bill.

The Bills Digest identifies that the Bill establishes a Ministerial pricing mechanism for NDIS supports and permits automated administrative decision-making within the NDIS. [3] The Department’s amendments material states that the Bill allows the Minister for the NDIS to determine maximum prices for NDIS supports, and that the amendment requires NDIA advice or summary advice relating to a pricing determination to be tabled in Parliament within five days of the Minister making that determination. [6] The NDIA pricing updates page states that the Bill proposes to provide the Minister with power to make a pricing determination. [8]

SWAA accepts that pricing must support Scheme sustainability. However, pricing is not just a number.

Pricing determines whether support work is viable, skilled, safe and sustainable. It affects whether providers can pay workers properly, provide supervision, deliver training, cover travel, maintain safe systems, complete documentation, respond to complexity, and remain available in rural and thin markets.

Support work is skilled work. It requires judgement, communication, boundaries, risk awareness, disability knowledge, emotional intelligence, documentation, safeguarding awareness, cultural awareness, trauma-informed practice and real-time decision-making.

If pricing does not reflect the true cost of quality support, the consequences are practical: reduced worker wages and conditions, less supervision, less training, reduced documentation time, fewer workers willing to take complex support roles, increased burnout, reduced continuity, more cancellations, less rural and remote availability, reduced small-provider viability, reduced participant choice, and increased risk to participant safety and support quality.

Pricing is therefore not only a workforce issue. It is a participant safety and continuity issue.

A pricing decision that looks efficient on paper may be unsafe in practice if it removes the conditions needed for skilled support work to occur. The NDIS cannot be secured by weakening the workforce that delivers it.

13. Plan management and support coordination reforms must protect choice, continuity and local knowledge

SWAA acknowledges the need to improve quality, integrity and conflict-of-interest safeguards in plan management and support coordination. However, commissioning and panel arrangements must not narrow participant choice, disrupt trusted relationships, or unintentionally favour larger providers over smaller, local and specialised providers.

Departmental guidance states that from 1 October 2027, the NDIA will establish a panel of plan management providers, and that only providers on that panel will be allowed to deliver plan management services. It also states that from 1 July 2028, the NDIA will appoint providers directly to deliver a new support coordination and connection service, meaning support coordination will not be funded individually in participant plans. [5]

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SWAA addresses these reforms because they are part of the reform package being implemented alongside the Bill and will interact directly with changes to planning, payment, provider regulation, claiming and participant choice.

For many participants, plan managers and support coordinators are not interchangeable administrative services. They may hold important knowledge about communication needs, preferred providers, local market gaps, cultural needs, family dynamics, risk history, trusted support relationships, rural and regional provider availability, participant goals, and what has and has not worked in the past.

A panel or commissioning model may improve quality if designed well. But if designed poorly, it may reduce choice, break trusted relationships, create transition stress, and narrow the market.

Choice and control cannot be protected in principle while being narrowed in practice. Participants should not be forced into a more controlled system without practical safeguards that preserve the relationships and local knowledge that make support work.

14. Functional capacity assessment must not become disconnected from real life

SWAA supports fair, consistent and evidence-informed access and planning processes. However, functional-capacity assessment must not become disconnected from real-life support need, risk and sustainability.

The Bills Digest identifies that Schedule 1 contains proposed access and planning amendments and a new definition of functional capacity. [3] Departmental guidance states that there will be no changes to access until 1 January 2028, and that from that date access will be based on a standardised, evidence-based assessment of functional capacity. [5]

SWAA understands the policy aim of consistency. However, consistency must not come at the expense of reality.

Proposed section 9B defines functional capacity in relation to an activity as a person’s ability to undertake that activity without assistance from other people, assistive technology or modifications, and in a context that excludes, as far as possible, the impact of the person’s environmental and personal circumstances. [2]

SWAA’s concern is that if this definition and assessment framework are not carefully designed and implemented, they may produce decisions that appear consistent on paper but fail to reflect real-life support need, risk and sustainability.

A person’s functional capacity may appear different depending on context, environment, support, stress, communication demands, fatigue, pain, trauma, sensory load, routine, transport, informal support, culture, housing and community accessibility.

A standardised assessment may capture some information. It may not capture what support workers often see: what happens on a bad day, how a participant functions when routines change, how capacity fluctuates, whether a person is masking distress, what happens when informal supports are absent, what is required for safe community access, how long a task can be sustained, whether a person can repeat a task safely over time, what happens during transitions, and how environmental barriers affect function.

SWAA does not suggest support workers should determine eligibility. That is not their role. However, where a participant consents, information from support workers and other trusted supporters should

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be able to inform assessment, planning and review because they may observe practical support needs that formal assessment does not capture.

The Committee should be careful about any framework that appears fair because it is standardised, but produces unfair outcomes because it misses context.

15. Automated administration must include human accountability SWAA recognises that digital systems and automated administrative processes can improve efficiency when they are carefully designed. SWAA does not oppose technology. SWAA opposes technology being used without enough human accountability, transparency, review rights and practical safeguards.

Departmental guidance states that the NDIA makes over 600,000 decisions about claims and payments every day, and that automation of certain administrative actions is considered necessary to support efficient operation. It also states that the Bill includes safeguards such as human oversight, CEO authorisation, use only where decisions are based on clear and objective rules, referral to a human decision-maker where judgement is required, preservation of review rights, and publication of a standard operating procedure instrument before it operates. [5]

These safeguards are welcome. They are not the end of the issue.

An automated decision or system error can have immediate practical consequences. It may delay payment to a sole trader. It may interrupt support. It may create stress for a participant who does not understand what has happened. It may place administrative burden on providers and workers to prove, correct or resolve something they did not cause.

For participants, workers and providers, the issue is not only whether automation is lawful. The issue is whether it is understandable, correctable and safe.

Technology should support human decision-making, not replace human accountability. The NDIS is not only a payments system. It is a human support system.

16. Implementation must include support workers One of SWAA’s strongest messages to the Committee is that implementation cannot succeed without the support worker workforce.

Government public guidance states that consultation will begin in the second half of 2026 on new framework planning, changes to assessment of eligibility based on functional capacity, commissioning approaches, differentiated pricing for unregistered providers, the Inclusive Communities Fund, and market reforms to social, community and capacity building activities. [5]

SWAA welcomes consultation. However, consultation must include the people expected to implement the reforms in real life.

Support workers will be expected to explain changes to participants in everyday contexts, adapt to changes in support hours, respond to reduced community access, provide records, navigate claiming changes, work within new provider registration and enrolment settings, support participants through assessment and plan changes, manage risk where supports are reduced or delayed, maintain continuity through transition, and keep delivering human support while the system changes around them.

Support workers are not peripheral to the NDIS. They are part of the infrastructure that makes the NDIS work.

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SWAA recommends the establishment of a formal Support Worker Reform Advisory Group to inform implementation of this Bill and related NDIS reforms. This group should not be for the benefit of any single organisation. It should exist because implementation will fail if the workforce expected to deliver the reforms is not included in their design.

Nothing for us without us must include participants. It must also include the support workers who stand beside them every day.

The NDIS cannot be secured without securing the human workforce that delivers it.

17. Practical illustrations of foreseeable impact The following are practical illustrations of foreseeable impacts. They are not identifiable case studies and are not presented as findings from a formal member consultation. They are included to assist the Committee to understand how the Bill and associated implementation settings may operate in real support settings.

Reduced community participation

A participant with psychosocial disability uses regular support worker assistance to leave home, attend community activities, maintain routine and reduce isolation. If social and community participation funding is reduced before safe alternatives exist, the participant may withdraw from community life, lose routine, become more isolated and require more crisis support later. The budget reduction may appear to reduce spending in the short term. In practice, it may shift risk to the participant, family, emergency services or other systems.

Urgent reassessment not activated early enough

A participant’s informal carer becomes unwell and can no longer provide daily support. A support worker notices missed meals, increased distress, cancelled appointments and reduced personal care. The participant is overwhelmed and does not request a reassessment. If only limited people can trigger the pathway, and if the urgent variation process is not clear, the situation may deteriorate before the NDIA responds. With participant consent, the support worker or provider should be able to contribute information early.

Plan suspension risk where contact fails

A participant with cognitive disability and unstable housing misses NDIA calls and letters. Their phone number changes and they do not understand the significance of written contact. The NDIA makes repeated contact attempts, but the person does not respond. Without active outreach and checks with known supports, the participant may lose access not because they no longer need support, but because communication failed. A safe system should find people before it suspends them.

Sole trader exits because compliance becomes too complex

An experienced independent support worker provides trusted community access and daily living support to several participants in a regional area. New registration, enrolment, record-keeping and claiming systems are introduced without plain-English guidance, templates, education or transition support. The worker decides the administrative burden and penalty risk are too high and leaves the sector. Participants lose a trusted worker. The local market becomes thinner. The reform improves compliance on paper but reduces access in practice.

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Pricing affects safety and continuity

A small provider supporting participants with complex needs faces pricing settings that do not cover supervision, travel, cancellations, documentation and training. The provider reduces supervision and stops accepting more complex referrals. Workers leave for more stable employment. Participants experience less continuity and fewer available skilled workers. Pricing that does not reflect real delivery costs can become a safety and access issue.

18. Conclusion and request to appear SWAA asks the Committee to recommend that the Bill not proceed in its current form unless amended to include enforceable safeguards for participants, support workers, ethical providers, thin markets and the continuity of high-quality human support.

SWAA is not asking Parliament to choose between sustainability and people. SWAA is asking Parliament to recognise that a sustainable NDIS depends on people: participants, families, support workers and ethical providers.

The NDIS is not secured by making community life smaller, making ethical workers fearful, or designing implementation without the workforce that delivers support every day.

The NDIS is secured when participants are safe, included and in control; when support workers are skilled, respected and supported; and when ethical providers can deliver high-quality support without being buried by unnecessary complexity.

Support work is skilled work. Support work is human work. It is essential to the wellbeing, inclusion and outcomes of people supported by the NDIS.

SWAA asks the Committee to recommend amendments that secure the future of the NDIS by securing the people at the heart of it: participants, families, support workers and ethical providers.

SWAA would welcome the opportunity to appear before the Committee at any further public hearing to provide practical evidence from the support worker and provider workforce perspective.

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References

1.​ Senate Community Affairs Legislation Committee, inquiry page: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Community_Affairs/NDISFu tureGenBill 2.​ ParlInfo, National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026, third reading version, House of Representatives, 2 July 2026. https://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id:%22legislation/bills/r748 7_third-reps/0000%22 3.​ Parliamentary Library, Bills Digest No. 65, 2025-26: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. https://www.aph.gov.au/Parliamentary_Business/Bills_Legislation/bd/bd2526/26bd065 4.​ Department of Health, Disability and Ageing, NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026. https://www.health.gov.au/our-work/ndis-legislation-changes/amendments/ndis-amendment-secu ring-the-ndis-for-future-generations-bill-2026 5.​ Department of Health, Disability and Ageing, About the changes to the NDIS. https://www.health.gov.au/our-work/ndis-legislation-changes/amendments/ndis-amendment-secu ring-the-ndis-for-future-generations-bill-2026/about-the-changes-to-the-ndis 6.​ Department of Health, Disability and Ageing, Changes to the NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 - fact sheet. https://www.health.gov.au/resources/publications/changes-to-the-ndis-amendment-securing-the-n dis-for-future-generations-bill-2026-fact-sheet?language=en 7.​ NDIS Quality and Safeguards Commission, NDIS workforce capability. https://www.ndiscommission.gov.au/workforce/workforce-capability 8.​ National Disability Insurance Agency, Pricing updates. https://www.ndis.gov.au/providers/pricing-and-payments/pricing/pricing-updates

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