Submission 2533
Submission
Proposed NDIS Reform Risks Gendered Safety and
Equality
Submission to the Senate Community Affairs Legislation Committee: National
Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations)
Bill 2026
JULY 2026
Women with Disabilities Victoria NDIS Amendment Bill 2026
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Publishing Information
The moral rights of the authors have been asserted.
Women with Disabilities Victoria [WDV] (2026). Proposed NDIS Reform Risks
Gendered Safety and Equality. Submission prepared for the Senate Community Affairs
Legislation Committee inquiry into the National Disability Insurance Scheme
Amendment (Securing the NDIS for Future Generations) Bill 2026. July 2026. Written
by Dr Brigid Evans, Manager, Policy and Evidence, Dr Trishima Mitra-Kahn, Chief
Executive Officer, and Ms Brigitte Stone, Communications and Policy Officer. Melbourne, Victoria.
Language Note
This submission uses ‘person first’ language (women and gender diverse people with disabilities). We acknowledge that people describe their experience of disability in different ways, and for many people, ‘identity first’ language is a source of pride and resistance.
Acknowledgement of Country
Women with Disabilities Victoria (WDV) respectfully acknowledges Aboriginal people as the Traditional Custodians of the lands and waters on which we work, rest, and continue to benefit from. We pay our respects to the Elders, past and present, of Aboriginal and Torres Strait Islander Communities across Victoria and acknowledge that their continued strength and resilience are built upon more than 60,000 years of history. The WDV community is committed to honouring the unique cultural and spiritual relationship Aboriginal and Torres Strait Islander peoples have with the land and waters, and their rich contribution to society.
Submission Contact
Dr Trishima Mitra-Kahn
Chief Executive Officer
Women With Disabilities Victoria (WDV)
E:
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About the Authors
Women with Disabilities Victoria (WDV) is a not-for-profit Disabled People’s Organisation (DPO) representing women and gender diverse people with disabilities in Victoria. The organisation is operated by and for women and gender diverse people with varied disability experiences. WDV has a diverse membership of people from different backgrounds. Women and gender diverse people with disabilities face intersecting forms of structural gender and disability discrimination.
WDV actively advocates for our rights to safety and respect, with particular emphasis on disability policy, health services, violence prevention, workforce development, and leadership. WDV envisions a world where all women and gender diverse people are respected and can fully experience life.
Key Contributors
Dr Brigid Evans, Manager, Policy and Evidence
Dr Trishima Mitra-Kahn, Chief Executive Officer
Ms Brigitte Stone, Communications and Policy Officer
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Background
As Victoria’s peak body for women and gender diverse people with disabilities, WDV’s gender perspective provides sector-leading, evidence-informed, and member-driven expertise on best practices for addressing critical inequities faced by women and gender diverse people with disabilities, including NDIS access and safety from gender-based violence.
WDV is deeply concerned that, if passed in its current form, this Bill will compound the gender inequalities already present within the NDIS and may put the lives, safety, and wellbeing of women and gender diverse people with disabilities at risk. Without adequate safeguards, viable alternative options, and policy guardrails, WDV is concerned that the Bill in its current form risks significant unintended consequences for women and gender diverse people with disabilities.
In our joint work, WDV and Our Watch established in Changing the Landscape1 that ableism and gender inequality are the two consistent, intersecting drivers of violence against women and girls with disabilities. WDV is concerned that the reforms proposed in the Bill’s current form risk exacerbating Driver 3 (controlling people with disabilities’ decision-making and limiting independence) and Driver 4 (social segregation and exclusion of people with disabilities).
For women and gender diverse people with disabilities who are NDIS participants, or who care for NDIS participants, equitable scheme access and social and community participation funding do so much more than support daily function. They can be the difference between being able to leave violence or not. They can be the difference between whether or not someone experiences violence in the first place.
“Governments have a primary responsibility for the health, safety, and equality of all women. They play a critical leadership role in addressing inequalities across Australian society and creating an enabling environment for systemic, structural, and large-scale change.”
Our Watch & Women with Disabilities Victoria. (2022). Framework for action to prevent violence against women and girls with disabilities: A resource for governments and policymakers. Melbourne, Australia: Our Watch. P. 14.
Our submission to the Senate Community Affairs Legislation Committee: National
Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations)
1 Our Watch & Women with Disabilities Victoria. (2022). Changing the landscape: A national resource to prevent violence against women and girls with disabilities. Melbourne, Australia: Our Watch. Women with Disabilities Victoria Page 4 of 21
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Bill 2026, therefore, focuses on an issue that warrants focused consideration by the Committee, being the potential consequences of the reforms on women and gender diverse people with disabilities who are experiencing or escaping gender-based violence.
In line with our core mission and values, WDV amplifies the voices of our members, whose lived experiences reinforce the gendered concerns identified in this submission, and illustrate the potential consequences of the proposed reforms in practice. To this end, our submission presents insights, questions, and concerns from a sample of 52 members across a range of ages, backgrounds, and geographic locations throughout Victoria. Responses from women and gender diverse people with disabilities illustrate gendered experiences of the NDIS and concerns arising from the proposed reforms.
As highlighted by our members, WDV also represents a cohort of women and gender diverse people with disabilities who have not been accepted as NDIS participants, have lost access to the NDIS, or may, for various reasons, including the associated stigma or potential administrative trauma, not have applied for NDIS participation, or contested their removal from the Scheme.
While WDV welcomes the opportunity to submit to this Senate Inquiry, it is important to note the impacts of the short turnaround time for the first and second rounds of submissions. The initial 15-day submission window did not provide adequate time for WDV to consult with or include members’ voices in an organisational submission. As a member-led organisation, WDV is committed to ensuring that our members’ voices are central to our advocacy. As such, we were unable to submit to the first round of this inquiry. Instead, WDV endorsed Women with Disabilities Australia’s (WWDA) submission.
Our submission does not seek to duplicate WWDA’s submission, which provided a detailed analysis of the gendered risks that may result from the proposed NDIS reforms. WDV continues to support WWDA’s submission and strongly advocates for the Government to act on WWDA’s analysis and recommendation. WDV further emphasises the need for greater consultation time to ensure that the unintended consequences of the Bill in its current form are understood and mitigated. Providing adequate consultation time is especially important in examining the potential impacts of these proposed reforms on multiply marginalised groups and meaningfully consulting with these cohorts.
As WDV has emphasised in our various submissions to past NDIS reviews and reforms, Australia is a signatory to the CRPD, and Article 6 recognises that women and girls with disabilities experience multiple and intersecting forms of discrimination. State Parties are required to take targeted measures to ensure the equal enjoyment of our
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rights and freedoms. To meet these obligations, the Australian Government must conduct comprehensive, public gender, violence, and safety impact analyses of the proposed NDIS reforms and embed co-designed gender-responsive reforms and rights-based principles into the foundations of the NDIS.
Recommendation 1: WDV recommends that the Bill not proceed in its current form without a comprehensive, public violence and safety impact analysis co designed and conducted in partnership with women’s disability peak bodies.
Recommendation 2: The Senate adopts WWDA’s recommendation that the Bill does not proceed in its current form without a comprehensive, public gender
impact analysis and co-design of gender-responsive reforms withwomen, girls, and gender diverse people with disabilities.
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- NDIS Reforms Must Understand and
Mitigate Drivers of Violence
WDV Member Insight
“I’m concerned that …changes in needs due to ’social reasons’, such as escaping violence, may not be taken into account. This does not recognise the social and human rights models of disability, which understand that people’s impairments and support needs are realistically impacted by their environments and personal circumstances, and this should be taken into account. It also means that accessible environments should be more of a priority for government funding, not just individual funding.”
The Royal Commission into Violence, Abuse, Neglect and Exploitation of people with Disability laid out in uncomfortable clarity that women with disabilities experience high rates of sexual assault, intimate partner, family and domestic violence, emotional abuse, and stalking.2 These rates are higher than those experienced by men with disabilities and women without disabilities. In fact, between the ages of 18 and 64, women with disabilities are roughly three times more likely to experience domestic partner violence and sexual assault than men with disabilities or two times more likely than women without disabilities.3
Rates of violence and abuse are particularly high for women with psychological or intellectual disabilities, with 72 per cent of women with psychological or intellectual disabilities having experienced violence or abuse since the age of 15 compared to 54 per cent of women with all forms of disability overall. Rates are also higher for young women with disabilities, who were twice as likely as young women without disabilities to have experienced physical violence, sexual violence, violence by an intimate partner, emotional abuse by a domestic partner, or stalking in the previous 12 months. Rates of violence and abuse are also higher for First Nations women with disabilities, nineteen per cent of whom have experienced domestic violence related crime since the age of 15 (compared to 8.6 per cent of First Nations men, and 5 per cent of non-First Nations women).4
Women with disabilities are more likely to know the perpetrator of violence, with 93 per cent knowing the perpetrator compared to 69 per cent of men with disabilities and 89 per cent of
2 Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. (2023) Final Report. 29 September, 2023. https://disability.royalcommission.gov.au/publications/final-report. 3 Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. (2023). Final Report Volume 3, Nature and Extent of Violence, Abuse, Neglect and Exploitation. September 29, 2023. https://disability.royalcommission.gov.au/publications/final-report-volume-3-nature-and-extent-violence-abuse neglect-and-exploitation. 4 Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. (2023). Final Report Volume 9, First Nations People with Disability. September 29, 2023. https://disability.royalcommission.gov.au/publications/final-report-volume-9-first-nations-people-disability. Women with Disabilities Victoria Page 7 of 21
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women without disabilities.5 Evidence given at the Royal Commission showed that women with disabilities have been sexually assaulted by support workers in supported accommodation and their own homes, or by support workers or fellow participants at day programs. They have also experienced sexual abuse or harassment in supported accommodation. Women with disabilities outlined the tactics used by perpetrators in contexts where support was being provided. These included deception and control, taking advantage of positions of trust, and taking advantage of women’s isolation and lack of independence in these settings.
WDV commends the Government for recognising the crisis facing our community and for acting on Royal Commission Recommendation 8.23, that the Australian Government should develop a five-year Action Plan for Women and Children with Disability to accompany the National Plan to End Violence against Women and Children 2022-2032. It is worth noting that the Disability Lens on the First Action Plan was published only this week (July 7, 2026), and consultations are currently underway for the Disability Lens on the Second Action Plan. WDV urges the Committee to provide sufficient time to ensure that the unintended consequences of this Bill in its current form do not undermine the vital recent and ongoing work being undertaken to broaden the ‘Government’s commitment to supporting women and children impacted by gender-based violence’6.
In its current form, the unintended consequences and risks for women and gender diverse people with disabilities experiencing, at risk of, or escaping violence, posed by the Bill in its current form are significant. WDV is particularly concerned by proposed section 40A. In its current form, the Bill proposes to allow the NDIA to suspend plans when it is seeking information from a participant who is not contactable. Before suspending a plan, the NDIA must make ‘reasonable attempts’ to contact the participant. If the participant remains uncontactable after 90 days, the NDIA can suspend their plan. These proposed changes significantly increase the consequences of participants being ‘uncontactable’, with limited safeguards in place.
This proposed reform may disproportionately affect Scheme access, wellbeing, and safety for women entering refuge or temporary supported accommodation. For example, in Victoria (and in many other States and Territories), when women or gender diverse people escaping violence enter refuge or temporary supported accommodation, to ensure their security, service providers complete a thorough ‘tech sweep’. This can involve pausing or ending previous communication methods, and in some cases, providing them with new mobile phones and SIM cards. Women and their dependent children can stay in refuges and temporary supported accommodation for months. Thus, under the proposed reforms,
5 Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. (2023). Final Report Volume 3, Nature and Extent of Violence, Abuse, Neglect and Exploitation. 6 Department of Social Services “Disability Lens on the First Action Plan 2023-2027.” Department of Social Services, July 7, 2026. https://www.dss.gov.au/national-plan-end-violence-against-women-and children/resource/disability-lens-first-action-plan-2023-2027-0. P. 12. Women with Disabilities Victoria Page 8 of 21
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women and children with disabilities residing in refuge or temporary supported accommodation who are uncontactable for their own safety risk losing access to NDIS supports at a time when such supports are at their most vital.
We must remember: the NDIS is not separate from violence prevention, nor from a recovery and healing response. It is not simply a Scheme that funds supports to improve daily functioning; for many women and gender diverse people with disabilities, it is an essential safeguard that enables safety, autonomy, and escape. NDIS supports can determine whether someone can leave a violent relationship, attend housing appointments, maintain privacy, access services, and avoid homelessness. When supports are delayed, suspended, or reduced, the consequences extend well beyond disability-related impacts and can increase exposure to violence, isolation, and dependence on perpetrators.
WDV Member Insight
“Women and gender diverse people with disabilities are already at significantly higher risk of violence, poverty, housing insecurity, and medical dismissal.“
It must also be noted that reducing funded supports does not remove the need for care. Rather, it transfers that care elsewhere. Most typically, it shifts caring, advocacy and coordination onto unpaid carers, who are overwhelmingly women. Many are women with disabilities or chronic health issues themselves and may have caring responsibilities for children with disabilities or ageing parents with disabilities. Reductions in funded supports, alongside cuts to social and community participation funding and increased administrative complexity, risk increasing unpaid labour, reducing workforce participation, undermining financial security, and contributing to burnout. For women and gender diverse people with disabilities experiencing or escaping violence, this loss of independence and agency can become another barrier to safety.
Financial insecurity further compounds safety risks. Women with disabilities already experience higher rates of unemployment and poverty than women without disabilities or men with disabilities.7 Reforms that risk reducing access to essential supports risk entrenching economic dependence and limiting opportunities to leave unsafe situations.
Community participation is also a critical protective factor. Access to work, education, social connection, and community activities reduces isolation and creates opportunities for abuse to be identified and addressed. For people living in supported settings, trusted community connections may be among the few external safeguards against violence, abuse, and neglect. Removing opportunities and funding for social and community participation, as proposed by
7 Olney, Sue, and Sophie Yates. “The Costs of Living with Disability in Australia: Accounting for Variable Disability‐Related Deprivation in Poverty Measures.” Australian Economic Review, June 26, 2025. https://doi.org/10.1111/1467-8462.70017; Commission for Gender Equality in the Public Sector. “Chapter 3 – Gender and Employees with Disabilities”. Intersectionality at Work. October 2023. https://www.genderequalitycommission.vic.gov.au/intersectionality-work/chapter-3-gender-and-employees disabilities. Women with Disabilities Victoria Page 9 of 21
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this Bill in its current form, reduces visibility, increases isolation, and weakens these protective factors.
WDV Member Insight
“How is removing consideration of someone’s social and environmental circumstances going to affect women escaping violence, or in rural and remote areas?”
This Bill, in its current form, does not adequately recognise the realities of family violence that are already impacted by current NDIS decision-making processes. Women escaping violence often experience sudden changes in housing, support networks, and care arrangements that require urgent and flexible responses. Current NDIS processes do not consistently recognise family violence as a basis for rapid plan reassessment. Further, current processes may create opportunities for perpetrators to misuse representative arrangements or access participant information and communication channels to exert coercive control after separation. Safeguarding arrangements must explicitly account for family violence to ensure participant safety, privacy and autonomy. WDV urges the Government to approach any NDIS reform in a way that identifies and mitigates threats to participant safety that may be present in current or proposed NDIS processes.
WDV is also deeply concerned by the expanded ministerial powers proposed by the Bill in its current form. Concentrating broad discretion in a single decision-maker to significantly alter participant access and supports may create unacceptable risks for women and gender diverse people with disabilities, particularly given the well-documented gender inequities already present within the NDIS. Without strong safeguards, transparency, and independent oversight, these powers risk exacerbating existing discrimination and producing unintended consequences for those already facing intersecting forms of disadvantage.
Finally, these reforms cannot be considered in isolation from the broader public narrative surrounding the NDIS. Public and political rhetoric framing participants as contributors to unsustainable Scheme costs has already fuelled stigma, ableism and targeted abuse, particularly towards women and gender diverse disability advocates. As WDV identified in our work with Our Watch on Changing the Landscape, gender inequity and ableism are the key intersecting drivers of violence against women and girls with disabilities. Driver 1 (negative stereotypes about people with disabilities) and Driver 2 (accepting or normalising violence, disrespect and discrimination against people with disabilities) are at risk of exacerbation within the current national dialogue. This risk may already be reality for many, with women and gender diverse people with disabilities reporting that they are experiencing increasing hostility both online and in the community, with their support needs routinely questioned and their identities attacked. Legislative reform must not reinforce narratives that further marginalise people with disabilities or embolden discrimination and violence.
Recommendation 1: WDV recommends that the Bill in its current form not proceed without a comprehensive, public violence and safety impact analysis
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co-designed and conducted in partnership with women’s disability peak bodies.
- Insights from WDV Members
WDV Member Insight
“I am worried that I am not going to meet the new NDIS eligibility… Without these I would not be able to function in the community and enjoy life in general.”
WDV surveyed 52 members following the announcement of the proposed NDIS reforms. A summary and analysis of the survey is provided in the Appendix.
Every respondent who commented expressed concern about the proposed changes. While members raised a wide range of issues, their responses consistently reflected four overarching themes:
the proposed reforms are perceived as unfair and poorly explained or inaccessible;
participants fear losing essential supports;
many believe the proposed changes will disproportionately disadvantage people already facing systemic barriers; and
respondents repeatedly questioned whether cost reduction is being prioritised over people’s safety, wellbeing, social and economic inclusion, and human rights.
Members’ responses also reveal significant uncertainty about how the proposed reforms will operate in practice. Many respondents questioned how functional capacity assessments would be conducted, who would lose access to the Scheme, how decisions would be made, and what supports would exist for people excluded from the NDIS if the Bill were to pass in its current form.
WDV Member Insight
“I’m concerned that the NDIS is going to focus solely on the management of the physical aspect of the disability, and less on the inclusion of people with disabilities in communities, organisations and society.”
Members repeatedly emphasised that the proposed reforms would not affect all participants equally. Respondents identified concerns for women and gender diverse people with disabilities who are carers, live in rural, regional, or remote areas, experiencing violence or poverty, or from First Nations or culturally and linguistically
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diverse backgrounds. WDV members recognised that existing inequalities shape who is most likely to lose access to supports and who has the least capacity to absorb those losses.
Throughout the survey, members consistently linked the proposed reforms to broader concerns about independence, community participation, employment, mental wellbeing, and safety. Many respondents viewed the proposed reforms as decisions with profound consequences for their ability to participate equally in society. Multiple members expressed frustration that the Government appeared to be targeting participants rather than combating fraud or improving the NDIS. Their responses reinforce the need for any proposed NDIS reform to be co-designed, informed by lived experience, underpinned by human rights principles, and assessed for its gendered and safety impacts.
WDV Member Insight
“Unless the government commits to providing universal, free health and medical care that is accessible, safe and available in rural and remote areas, they can’t say that they’ll bar people from the NDIS if they haven’t undertaken [every possible treatment option]. It’s actively excluding poor, rural, and non-English speaking people, not to mention women who are dismissed by doctors and never given the opportunity.”
- WDV Supports WWDA’s
Recommendations
WDV Member Insight
“What safeguards will be in place to ensure women, gender diverse people, First Nations communities, CALD communities, and survivors of trauma or FDV are not disproportionately impacted by reforms?”
WDV strongly supports WWDA’s submission to this Inquiry. WWDA’s submission highlights the gendered risks that may result from the proposed changes. WDV is concerned that the proposed reforms could create significant risks for women and gender diverse people with disabilities by proposed changes to eligibility requirements, increasing centralised decision-making powers, and introducing new approaches to assessment, funding, and evidence before appropriate safeguards are in place.
WDV shares WWDA’s concern that the proposed reforms are progressing without a comprehensive gender impact assessment. This is despite longstanding evidence that
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women8 are already underrepresented in the NDIS and face significant barriers to accessing diagnosis and disability supports. Women make up more than half of Australians with disabilities, but only around 37–38% of NDIS participants. These inequities are well documented, yet the proposed reforms have not been developed or assessed through a gender-responsive lens.
WDV Member Insight
“One of my biggest concerns about the announced NDIS changes is how they may disproportionately impact people …already facing systemic disadvantage. Women, gender diverse people, First Nations communities, CALD communities, people with trauma histories, survivors of family and domestic violence, and people with co-occurring conditions often experience additional barriers when trying to access disability supports and healthcare.”
WDV also agrees with WWDA that the Bill in its current form seeks to introduce broad legislative powers before key details, including rules, assessment tools, budget approaches, foundational supports, and safeguards, have been developed or publicly examined. This creates significant uncertainty for participants and limits Parliament’s ability to understand the practical impacts of the proposed reforms before granting extensive powers.
WDV particularly supports WWDA’s finding that the greatest risks do not come from any single part of the Bill in its current form, but from the combined impact of multiple proposed reforms. Existing gender inequalities may be deepened by the interplay of tighter eligibility requirements, functional capacity assessments, reassessments, increased decision-making powers, reduced access to supports, greater reliance on other service systems and unpaid care, and the absence of fully established and tested foundational supports. The full extent of any unintended consequences cannot be understood by considering each proposed reform separately.
WDV Member Insight
“Requiring there to be published, generalisable and peer-reviewed research evidence on the effectiveness of supports is unjust for women and girls, who have not been included as research participants in most medical research. It also means under-researched conditions that typically impact women may end up being further marginalised in the scheme.”
8 Insufficient data exists regarding equality of access for transgender and gender diverse people with disabilities. A comprehensive gender impact analysis must include a specific review of the potential impacts the proposed reforms on these cohorts. Women with Disabilities Victoria Page 13 of 21
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WDV, therefore, supports WWDA’s recommendation that the Bill in its current form should not proceed without a rigorous, transparent, and forward-looking gender impact assessment. This assessment should identify who may be disadvantaged by the proposed reforms, examine the combined impacts and unintended consequences of the proposed changes, and ensure appropriate safeguards are in place.
WDV also supports WWDA’s recommendation that proposed reforms be co-designed with women and gender diverse people with disabilities, and that the Government demonstrate that effective foundational supports, transparent assessment processes, and gender-responsive safeguards are in place before participants are redirected away from the NDIS or lose access to supports.
Recommendation 2: The Senate adopts WWDA’s recommendation that the Bill, in its current form, not proceed without a comprehensive, public gender impact analysis and co-design of gender-responsive reforms with women, girls, and gender-diverse people with disabilities.
Appendix 1: Have Your Say: NDIS Changes
Survey Data
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Purpose and Structure
This appendix supplements WDV’s submission to the Senate Community Affairs
Legislation Committee: National Disability Insurance Scheme Amendment (Securing
the NDIS for Future Generations) Bill 2026, presenting insights from members of our organisation based on their lived experience of the NDIS. This material will provide a snapshot of experiences from a sample of 52 members across a range of ages, backgrounds, and geographic locations.
Comments and responses from women and gender diverse people with disabilities are presented to illustrate gendered experiences of the NDIS and concerns arising from the proposed reforms.
Methods
Data Collection
A ten-question survey was open on SurveyMonkey for four weeks (May 20 to June 18). It included seven demographic questions, one drop-down question, and two open text box questions. The survey received 51 direct responses. An additional response was provided via email to support accessibility.
Participant Recruitment
Participants were recruited via the WDV newsletter, an email to the WDV Members’ mailing list, and WDV’s social media pages.
Limitations
Due to WDV staffing and funding constraints, an Easy Read survey was not produced. As such, the data collected may not reflect the breadth of women and gender diverse people with disabilities’ experiences. In particular, the voices of women and gender diverse people with intellectual disabilities, acquired brain injury and others who may require Easy Read will not be fully reflected in this submission.
Time restrictions also limited our capacity to produce versions of the survey in languages other than English, to conduct offline surveys, or to ensure culturally inclusive engagement for our First Nations members. As such, survey data may not reflect the experiences of our members from First Nations or culturally, racially, and linguistically marginalised backgrounds, or those with limited or no internet access due to financial or rural connectivity constraints.
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WDV recommends that the inquiry into the proposed changes be extended to enable consultation with and submissions from these cohorts.
Respondents’ Demographic Profile
Responses came from members over the age of 25 with a range of disability experiences. Most responses (80.39%) came from members who identified as having more than one type of disability. The survey did not receive responses from members who identify as Aboriginal or Torres Strait Islander. Two respondents spoke a language other than English at home, and three were born outside of Australia.
57% of respondents were current NDIS participants. Other respondents included parents of NDIS participants, ineligible individuals, and individuals waiting for assessments or appeal outcomes.
Survey Findings
Question 8 Respondents were asked to identify which element of the proposed NDIS changes they would most like the Government to clarify. Standardised functional assessments to determine NDIS eligibility: 20 responses (47.62%)
Support coordination and plan management: 7 responses (16.67%)
Other (please specify): 7 responses (16.67%)
Registered and unregistered providers: 4 responses (9.52%)
Unscheduled Plan reassessments: 4 responses (9.52%) Digital payment systems: 0 responses (0.00%) I do not want or need anything clarified: 0 responses (0.00%) I prefer not to respond: 0 responses (0.00%)
Other elements respondents wanted clarity on included; all listed areas: 1 response decision-making rationale: 2 responses eligibility criteria: 4 responses Social and community inclusion activities: 1 response Accessing the NDIS: 1 response Removal from the NDIS: 2 responses Women with Disabilities Victoria Page 16 of 21
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Question 9 Respondents were asked what concerns they had about the proposed NDIS changes. All responses were negative or expressed significant concerns about the proposed NDIS changes. Concerns centred on the proposed reforms being unfair or unjust (46), loss of eligibility, funding, supports, or preferred providers (39), impacts on wellbeing, independence, and safety (27), disproportionate impact on certain cohorts (24), and lack of clarity or accessibility (10).
No respondents expressed positive sentiment about the proposed changes.
For ease of reporting, concerns raised in Question 10 have been merged with responses to Question 9.
Concerns expressed by respondents:
The proposed reforms are unfair or unjust (46 responses)
Assessment and eligibility processes will be unfair, inconsistent or inappropriate: 10 respondents
The proposed reforms prioritise cost-cutting over people’s wellbeing and rights: 8 responses
Provider fraud and system waste should be addressed instead of reducing participant supports: 6 responses
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The proposed reforms may breach human rights, dignity or disability rights principles: 5 responses
People with disability have not been meaningfully consulted or involved in co-design: 5 responses
The proposed reforms may increase administrative burden, bureaucracy or complexity: 3 responses
Automated or standardised decision-making (including AI) may produce poor decisions: 3 responses
The proposed reforms may force people into inappropriate or harmful treatments: 2 responses
Review, appeal and procedural fairness protections may be weakened: 2 responses
Privacy, surveillance and monitoring of participants are concerning: 2 responses
Loss of eligibility, funding, supports, or preferred providers (39 responses)
People may lose eligibility for the NDIS or be excluded from supports: 11 responses
Funding cuts or reduced plans may leave people without essential supports: 11 responses
People who lose NDIS access may not be adequately supported by mainstream services: 5 responses
Independent, unregistered or small providers may be negatively affected by compulsory registration: 5 responses
Participants may lose trusted providers or continuity of support: 5 responses
Transport and mobility supports may be reduced: 2 responses
Impacts on wellbeing, independence, and safety (27 responses)
Supports for social participation, independence and quality of life may be reduced: 8 responses
Participants may lose independence, employment or ability to participate in community life: 7 responses
People may experience increased stress, anxiety, fear and uncertainty because of the proposed reforms: 6 responses
Mental health, wellbeing and safety may deteriorate because of reduced supports: 6 responses Women with Disabilities Victoria Page 18 of 21
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Certain cohorts may be disproportionately disadvantaged by the proposed reforms (24 responses)
People with invisible, psychosocial, fluctuating, episodic or complex disabilities may be unfairly disadvantaged: 9 responses
Regional, rural, remote or disadvantaged groups may be disproportionately affected: 5 responses
Women, gender-diverse people and people experiencing multiple forms of disadvantage may be disproportionately affected: 4 responses
People with disabilities caused by transport accidents or workplace injuries may fall through gaps: 3 responses
Children and young people may be adversely affected by the proposed reforms: 3 responses
Lack of clarity or accessibility (10 responses)
There is insufficient clarity or transparency about the proposed reforms: 6 responses
Government communication about the proposed reforms is inaccessible or difficult to understand: 4 responses
Question 10 Respondents were asked if they had any questions about the announced proposed changes to the NDIS. Respondents expressed significant fear, uncertainty, and exhaustion, with key questions reflecting concerns about potential funding reductions, opaque decision making processes, human rights impacts, and impacts on already disadvantaged participant cohorts.
Many questioned how eligibility would be determined and sought clarity on functional capacity assessment processes. Many raised serious concerns about transparency, equity, continuity of care, and whether people with disabilities had been involved in the design or decision-making related to the proposed reforms. Respondents questioned how the Government would ensure that already disadvantaged cohorts would not be disproportionately affected by the proposed reforms. Many also questioned how participants’ safety, human rights, and social or economic access would be protected, especially if people are removed from the NDIS before appropriate alternative supports are in place. Several respondents requested clearer communication and guidance, and that all information be available in Easy Read.
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For ease of reporting, questions raised in response to survey Question 9 have been merged with Question 10.
Respondents asked:
How would decisions be made? (39 responses)
How would eligibility, functional capacity assessments and reassessments work (criteria, who assesses, frequency, implementation)? 14 responses
Who would lose access to the NDIS or be excluded under the proposed reforms? 11 responses
How would funding reductions, plan budgets and support allocations be determined? 10 responses
Would automated decision-making or AI be used? 2 responses
Would review and appeal rights remain? 2 responses
Who would be affected? (29 responses)
How would people with invisible, psychosocial, fluctuating, episodic, progressive, degenerative, or complex disabilities be affected? 9 responses
How would provider registration affect independent or unregistered providers? 6 responses
Who would be affected and what exactly will change? 5 responses
How would women, gender-diverse people and other disadvantaged groups be impacted? 5 responses
How would children, young people and people with developmental delay be supported? 4 responses
How would the proposed reforms be designed or assessed? (23 responses)
How would people with lived experience be involved in consultation, co design and decision-making? 6 responses
How would interactions with other systems (Aged Care, TAC, WorkCover, mainstream services) work? 5 responses
How would provider fraud and misconduct be addressed? 4 responses
How would the impacts and outcomes of the reforms be monitored or evaluated? 4 responses
How would the government mitigate any increased administrative burden or complexity for participants? 2 responses
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How would privacy, surveillance and participant information be handled? 2 responses
How might supports be affected? (22 responses)
What support would exist for people who might lose eligibility or have reduced supports? 6 responses
Would participants be able to keep their existing providers, therapists, or support workers? 5 responses
What would replace community participation and social support funding? 5 responses
How would continuity of care and long-term supports be maintained? 4 responses
How would transport supports/funding be affected? 2 responses
Why is the Government proposing to reform the NDIS in this way? (22 responses)
Why are these proposed reforms being made? 8 responses
Why seemingly target participants rather than purely target fraud or waste? 7 responses
Can clearer, more accessible information be provided about the proposed reforms, including in Easy Read? 4 responses
How can the proposed reforms be challenged, stopped or changed? 3 responses
How might people be affected? (13 responses)
How will participants be able to remain in work, education and community life? 4 responses
How might women and gender diverse people experiencing or escaping violence be affected? 3 responses
How will regional, rural, and remote participants be supported? 3 responses
Does the Bill in its current form breach human rights or Australia’s obligations under the UN CRPD? 3 responses
Women with Disabilities Victoria Page 21 of 21