Inquiry into the NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 2534

SUBMISSION TO THE SENATE COMMUNITY AFFAIRS COMMITTEE

Inquiry into the NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026

July 2026

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Submission 2534

Founded in 1952, genU is one of Australia’s largest disability and community service providers, and the fourth largest NDIS provider. We support 49,000 people each year through a workforce of more than 5,000 employees.

Operating across metropolitan, regional and rural communities, genU delivers a broad range of services including Supported Independent Living (SIL), community participation, employment, training, allied health, aged care and community services.

genU supports NDIS reforms that improve scheme sustainability, quality and value. However, reductions to social and community participation funding must be evidence-based and risk informed. A blunt approach to these reforms risks removing preventative supports that are currently reducing pressure on families, hospitals, crisis services, housing systems and other public supports.

genU would greatly appreciate the opportunity to appear before the Senate Committee to discuss our submission and recommendations further, and to answer any questions Committee members may have.

If Committee Members would be interested, we would also be pleased to host visits to any of our services and introduce you to some of our participants, to provide direct insight into the delivery and experience of disability support and care.

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Submission 2534

THE REAL IMPACT ON NDIS PARTICIPANTS

genU supports NDIS participants with significant functional support needs. The following examples are just four of our participants who rely on our programs and supports to enable and maintain communication, safety, emotional regulation, routine, social connection, carer sustainability and community inclusion.

They demonstrate that social and community participation funding is not a uniform or discretionary category of support, but a complex, individual and integral enabler of their quality of life.

HARRISON

For Harrison, community participation is a disability support that helps him maintain emotional wellbeing, routine, social connection and meaningful participation in community life, while also supporting the sustainability of his family’s caring role.

“Adventure is not just an activity. It is where I feel included, connected and happy. Without it, I would lose time with my friends, lose part of my routine, and lose a place where I feel safe and supported.”

Harrison’s Harrison experiences communication challenges, anxiety associated with functional and uncertainty and change, and relies heavily on routine, familiar environments and trusted supports. disability support needs Harrison has significant disability-related support needs affecting communication and emotional regulation. He requires predictability, familiar environments and trusted relationships to manage anxiety and participate safely and confidently.

Harrison’s Harrison attended genU’s Adventure program 5 days/week (30 hrs/week) for current support around 15 years. Recently, Harrison’s NDIS funding was reduced by $26,000. He now attends Adventure 3 days/week (1:3 support) while his funding is under review.

What the support genU’s Adventure program provides a safe and familiar environment for provides for Harrison and is one of his primary opportunities to build friendships and social connection outside his family network. Harrison and his family Adventure also provides verbal prompting, emotional regulation support, supervision and communication support (expressive communication and understanding conversational meaning), within a predictable, familiar routine that builds trusted friendships and community inclusion.

An Occupational Therapist report shows improved independence using public transport, and his friendship circle has grown, including phone contact with friends outside program hours.

Being able to attend the Adventure program reduces Harrison’s reliance on family as his sole source of social connection and reassurance. It also helps sustain the caring capacity of Harrison’s family by ensuring he has

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Submission 2534

opportunities for participation and connection beyond the home environment.

Why NDIS Despite the reduction in funding, Harrison’s support needs have not reduced funding matters and his need for routine, communication support and safe community connection remains unchanged. This funding sustains his wellbeing, his for Harrison hard-won independence gains and his family’s caring capacity.

If support is Since learning of the funding reduction, Harrison has demonstrated reduced for increased anxiety and distress, and repeated statements like “My funding has been cut”. Harrison If support for Harrison is reduced further, risks include:

• Increased social isolation and loss of established friendships and peer relationships

• Heightened anxiety, repetitive distress and reduced emotional regulation

• Greater dependence on family members and pressure on informal carers

• Loss of hard-won gains in independence and confidence, including recent progress with independent public transport use.

MARCUS

Marcus’s story is one of rebuilding – six months sober, in stable housing, and finally able to be the father and husband he wants to be as a result of the structured support received.

“Accessing NDIS supports was the first time I felt like I had a real chance to move forward… The centre-based capacity-building program I attend through GAMER has become one of the most important parts of my week. It gives me routine, structure and somewhere I belong…That stability has changed my life. Since engaging with GAMER and my broader supports, I have maintained sobriety, sustained stable housing, reduced my reliance on crisis and acute mental health services, and started working towards employment readiness. These are not small changes. They are the difference between the life I was surviving and the life I am now building.”

Marcus’ Marcus has ADHD, Autism Spectrum Disorder and demand avoidance, not functional and diagnosed until his mid-twenties. disability support He has needs affecting his emotional regulation, executive functioning and needs routine management, interpersonal and social skills, and needs support to maintain recovery and daily living stability.

He also has a history of alcohol and other drug use, unstable housing and reliance on crisis and acute mental health services prior to receiving appropriate support.

Marcus’ current Marcus attends genU’s GAMER program 2 days/week (6 hrs/week) with 1:4 support support. He also accesses psychology, occupational therapy, support

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Submission 2534

coordination, plan management, cleaning support and personal support workers.

What the support The structure, routine and trusted relationships GAMER provides gives provides for Marcus the support to show up consistently, without it feeling like a battle. Marcus and his The program provides supervision, emotional regulation support, family interpersonal skills development, routine and time-management support, creative outlet opportunities, and peer and community engagement.

Marcus’ attendance has risen from 20% to 80%. He has now sustained six months of sobriety and stable housing, and reports greater self-security, healthier decision-making and stronger coping strategies for stress and anxiety. After years of social isolation, he has also rebuilt an informal support network and community connection.

Marcus is a husband and father to two children, one of whom also lives with disability. He describes his stability as directly improving his capacity to parent, with greater patience, presence and pride. His family’s wellbeing depends on him remaining regulated and supported.

Why NDIS Marcus’ progress reflects the effectiveness of consistent support. His funding matters recovery is still new and remains dependent on this structure. Funding cuts have already ended his engagement with allied health services, and he has for Marcus reported increased anxiety and fear of losing the stability he has built.

Continued funding sustains his recovery and his family’s stability and reduces the risk of a return to crisis and higher-cost systems.

If support is If support for Marcus is reduced further, risks include: reduced for • Relapse into alcohol or other drug use, and renewed reliance on crisis or Marcus acute mental health services

• Loss of housing stability and reduced progress towards employment readiness

• Deterioration in family functioning and reduced capacity to parent his two children

• Greater cost-shifting to health, housing, crisis, and child and family services.

CAMERON

For Cameron, community participation is not recreation. It is the support that maintains his safety, emotional regulation and family stability, while reducing the risk of more intensive, costlier supports.

“One of the most important parts of my life is attending genU… I enjoy seeing familiar people and being part of a community where people know and understand me. Knowing where I am going and what I will be doing helps me feel safe and settled. When my routine is disrupted or I become distressed, life can become much harder for me. Having meaningful things to do each day helps me stay connected, engaged and calm.”

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Submission 2534

Cameron’s Cameron has an intellectual disability, Developmental Epileptic functional and Encephalopathy with Spike Wave Activation in Sleep (DEE-SWAS), and Autism.disability support needs He has support needs for non-verbal communication, emotional regulation, continual supervision, personal care and safety in community settings. He has elevated risk of physical injury from self-injurious behaviour due to co occurring osteoporosis and scoliosis.

Cameron’s Cameron attends genU’s Participate program 5 days/week (31.75 current support hrs/week). He has consistent 1:1 support, attending since 2016.

What the support Cameron relies on familiar staff who understand his communication style provides for and behavioural triggers, enabling early intervention that prevents escalation into self-injury. Without this support, he cannot safely access community lifeCameron and his or maintain the routine that underpins his stability.family He needs communication support, emotional regulation, structured routine and behavioural support, including monitoring for distress and self-harm; health management for epilepsy, osteoporosis and scoliosis; full personal care assistance; full community supervision (incl. roads/transport); and PRN medication and protective helmet for head-hitting episodes.

For Cameron, these supports are a critical part of the disability support framework that helps maintain his safety, emotional wellbeing, communication, community participation and overall quality of life.

Over the past three years, incidents have reduced from eight to five, and he has had no hospital or Crisis Assessment Team (CAT) admissions while attending genU. This is evidence that consistent support, not reduced need, drives the improvement.

Cameron’s parents provide extensive daily care. His mother lives with chronic pain, reduced mobility and the impacts of spinal fusion surgery. Community participation supports provide Cameron’s family with critical respite and enables them to manage their own health, appointments and household responsibilities.

Why NDIS For Cameron, these supports are a critical part of the disability support funding matters framework that helps maintain his safety, emotional wellbeing, communication, community participation and overall quality of life.for Cameron NDIS funding maintains Cameron’s safety and wellbeing while enabling his parents to keep caring for him at home. Without it, his family may have no option but to pursue costlier SIL housing for Cameron, on safety grounds for him and his sister.

If support is If support for Cameron is reduced, risks include: reduced for • Serious self-injurious behaviour and physical injury; emotional distress Cameron and loss of routine

• Increased safety risk to other family members, including Cameron’s younger sister

• Greater reliance on crisis responses and higher-cost interventions

• Earlier transition to Supported Independent Living (SIL) and at substantially higher cost, likely needing to be expedited on safety grounds.

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Submission 2534

JACOB

For Jacob, genU’s community participation programs reduces Jacob’s dependence on his father as his sole source of support and community connection.

“For me, genU is not just somewhere I go during the day. It helps me stay active, see people, do the things I enjoy and be part of my community.”

Jacob’s Jacob has Autism Spectrum Disorder (Level 3) and intellectual disability. He functional and is non-verbal, and requires substantial support with communication, emotional regulation, safety awareness and community participation. disability support needs Jacob has a history of absconding, physical aggression when distressed, and inappropriate social behaviours when under-stimulated or socially isolated.

Jacob’s current Jacob attends genU’s day programs 5 days/week (30 hrs/week), with support consistent 1:1 support since 2021.

What the support Routine and meaningful engagement are essential protective factors for provides for Jacob. When he has access to structured activities, familiar support workers and predictable routines, he is better able to regulate his emotions Jacob and his and participate safely in community life. family Jacob receives 1:1 supervision and safety support in the community (including absconding and road-safety risk); support to access preferred activities (swimming, bowling, discos); emotional regulation through structured routine; behaviour support to reduce distress and aggression; communication support via visual schedules, gestures and behavioural cues; transition support; capacity-building in daily living skills; and social skills development.

Without the funding for a program like genU offers, Jacob would be completely dependent on his father. He has since formed a close friendship with a fellow non-verbal participant and they now walk to and from programs together, communicating through gesture and body language.

He has also progressed from refusing to engage in music lessons to an enthusiastic participant who plays drums and dances with peers. This is a significant social skills gain against his NDIS goals.

Jacob’s father provides significant daily care and supervision. Reduced funded supports would increase caring demands, supervision requirements and family stress, while reducing the sustainability of current living arrangements.

Why NDIS Jacob needs 1:1 support to safely access the community, participate in funding matters activities and manage the risks associated with his behavioural support needs. for Jacob

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Submission 2534

The gains Jacob has made, including a close friendship and his engagement in music and dance, reflect the effectiveness of consistent, structured support.

This funding keeps Jacob safe in the community and sustains his father’s capacity to care for him at home.

If support is If support is reduced for Jacob, risks include: reduced for

• Behavioural escalation, including absconding and physical aggression

Jacob

• Loss of hard-won social gains, including his friendship and music participation

• Increased social isolation and loss of daily living and independence skills

• Greater pressure on his father and earlier need for more intensive support arrangements as Jacob ages.

EXECUTIVE SUMMARY

genU supports the overall intent of the NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026. However, we believe it is critical that any reforms ensure funding, planning and service delivery settings work together to support participant safety, continuity of care and workforce sustainability.

As one of Australia’s largest disability and community service provider, and the fourth largest NDIS provider, our scale and breadth gives us a unique view of how policy changes flow through the full support ecosystem, and the firsthand impacts on Australians with disability.

genU designs services around whole-of-person outcomes, not by funding streams. We do this purposefully, as this is in line with how participants experience care – as a connected system of support, not as individual components.

This means that when a funding change in one part of the system limits a participant’s ability to access support in another, or a planning decision affects workplace capacity, genU sees those impacts directly.

Our primary concern with the Bill is around the collective impact of concurrent changes to funding, eligibility settings, new framework planning, pricing arrangements, SIL commissioning and foundational supports.

Based on our experience delivering supports at scale and reflective of the practical realities of supporting participants with complex needs across multiple services, we have six recommendations to strengthen the draft legislation:

• Stage implementation to avoid disruption for participants and providers
• Require independent evaluation before major funding and support changes are introduced
• Ensure functional assessments lead to fair and consistent support decisions
• Establish sustainable pricing that reflects the actual cost of delivering supports
• Increase transparency and accountability in NDIS decision-making
• Protect participant safety and service continuity during reform implementation. Page 8 of 13

Submission 2534

GENU’S KEY CONCERNS

Supported Independent Living and continuity of supports

Relevant provisions:

• Schedule 1, Part 4 (Support Determinations)
• Schedule 4 (New Framework Planning)
• Schedule 5 (Transitional Arrangements) For many participants supported by genU, Supported Independent Living (SIL) does not operate as a standalone support. It relies on interconnected funding arrangements across home and living supports, community participation, transport, employment and daily activities that collectively enable safe and sustainable service delivery.

Of particular concern is the interaction between proposed support determinations and broader reductions to Social, Civic and Community Participation (SCCP) funding.

For many SIL participants, SCCP funding supports daytime activities, supervision, personal care and community access that sit alongside funded home and living supports. These are critical to ensuring social engagement, reducing isolation, and supporting connection to community and general quality of life.

As a provider supporting many participants with complex and high support needs, genU is concerned that the proposed funding reforms will weaken continuity of supports if implemented without careful impact assessments and appropriate transition arrangements.

Participant safety and service continuity must remain the primary measure of success. Reducing or removing day program funding without addressing the resulting coverage gap risks leaving some of the scheme’s most complex participants without appropriate daytime supports.

SIL funding is not intended to replace structured day supports, community participation or capacity building programs. Without these services, participants may face increased safeguarding risks, loss of routine and community connection, behavioural deterioration and reduced wellbeing, while families and providers are left managing support needs that have not disappeared simply because funding arrangements have changed.

Whole-of-person outcomes, community participation and employment

Relevant provisions:

• Schedule 1, Part 4 (Support Determinations)
• Schedule 1, Part 6 (Reasonable and Necessary Supports)
• Schedule 4 (New Framework Planning) genU designs services around whole-of-person outcomes, not by funding streams. This reflects how participants experience and engage with care. That is, through an interconnected system of supports that enables them to live independently, build relationships, participate in their communities, access employment and maintain wellbeing.

Community participation supports are, therefore, not discretionary for genU’s participants. Each of the case studies included in this submission demonstrates that the support received is directly linked to a disability-related functional need and not a diagnosis. The relevant functional domains include communication, emotional regulation, safety and mobility in community settings, decision

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Submission 2534

making, and the sustainability of family and carer arrangements. On this basis, these supports meet the “reasonable and necessary” test. They are necessary to enable participants to pursue their goals and participate in social and economic life, and without them, participants cannot safely or independently access their communities.

Reducing or removing these supports does not reduce the underlying functional need; it shifts that need onto other systems. Where community participation supports are withdrawn, the evidence in this submission shows the resulting pressure does not disappear – it moves to hospitals, families and carers, mental health services, and in some cases justice and crisis response systems. This is inappropriate and ineffective substitution of services.

Inclusion and participation are not optional extras for people with disability. They provide participants with safe, independent access to community life. Many participants do not have access to alternative community-based supports outside the NDIS. Reforms should strengthen participation and inclusion, not create barriers to them.

Planning, assessment and access to supports

Relevant provisions:

• Schedule 1, Part 1 (Functional Capacity)
• Schedule 1, Part 2 (Plan Reassessments)
• Schedule 1, Parts 8 and 9 (Permanence Eligibility) genU supports efforts to improve consistency and transparency in planning, assessment and eligibility decisions. However, planning systems must have flexibility and remain responsive to the realities of participants whose needs may fluctuate or deteriorate over time.

Many genU participants live with complex and intersecting conditions that may not be easily captured through standardised assessment frameworks. Functional capacity, permanence and eligibility reforms must be designed and tested against real participant outcomes, particularly for people requiring intensive supports or living with complex conditions.

Providers are often the first to identify changes in participant circumstances or emerging risks and should continue to play a role in supporting participant wellbeing and continuity of care.

System readiness and reform sequencing

Relevant provisions:

• Whole of Bill
• Schedule 4 (New framework Planning)
• Schedule 5 (Transitional Arrangements) genU has concerns around whether the broader disability ecosystem is ready to absorb multiple reforms safely and effectively.

Participants, providers and governments are simultaneously preparing for changes to funding, planning frameworks, pricing arrangements, SIL commissioning, and foundational supports. While these changes are individually important, their combined effect altogether creates heightened risks to participant outcomes, workforce sustainability and service continuity if implementation occurs before replacement systems and supports are operational.

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Submission 2534

genU strongly believes implementation should be guided by demonstrated system readiness, with reform sequencing informed by participant outcomes, workforce capacity, service continuity and provider sustainability, with all efforts taken to avoid a commencement date that creates unreasonable burden, unintended consequences, and risk.

Continuity and stability in the interests of participants must remain central considerations throughout the reform process.

Sustainable service delivery and workforce capacity

Relevant provisions:

• Schedule 3, Part 1 (Pricing Determinations)
• Schedule 4 (Funding Methodologies and Budget Frameworks) A sustainable NDIS requires a sustainable provider market. Participants can only benefit from the reforms if providers remain able to deliver the scale and high-quality services over the long term.

The Bill introduces significant changes to pricing and funding arrangements at the same time as broader reforms affecting participant plans, service delivery and market structures. These pricing decisions directly influence workforce investment, service quality, regional service availability and continuity of supports.

genU believes pricing and funding arrangements must reflect the true cost of delivering safe and sustainable supports, including workforce costs, supervision requirements, compliance obligations and additional challenges associated with regional service delivery and complex participant cohorts.

Sustainable pricing is fundamental to participant safety, service continuity and long-term viability of the Scheme.

GENU’S RECOMMENDED AMENDMENTS

genU supports the intent of the NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026, however believes amendments are needed to strengthen it, and support safe, evidence based reform that delivers sustainable outcomes for participants, providers and the broader Scheme.

1. Stage implementation to avoid disruption for participants and providers Relevant provisions: whole of Bill

The Bill introduces significant changes across funding, eligibility, assessment, pricing and market arrangements. These reforms do not occur in isolation, and implementation should be guided by system readiness, including:

• availability of replacement supports and service pathways
• workforce and provider capacity
• operational readiness of new planning and assessment systems
• pricing arrangements that reflect cost of safe and sustainable services
• mitigation plans where unintended gaps in supports identified, particularly in regional and rural communities.

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Submission 2534

genU recommends that, before implementation of major reform milestones commence, the Department of Health, Disability and Ageing and the NDIA be required to demonstrate system readiness, ensuring operational, workforce, funding, planning and safeguarding arrangements are all in place and functioning as intended.

2. Require independent evaluation before major funding and support changes are introduced Relevant provision: Schedule 1, Part 4 (Support Determinations)

Before any determination to reduce funding across categories of supports takes effect, the NDIA should be required to publish on its website an independent impact assessment and evidence, which considers (at a minimum):

• participant safety outcomes
• continuity of supports
• impacts on SIL arrangements
• workforce sustainability
• provider viability
• impacts on regional and rural communities
• potential unintended costs shifting to health, housing, aged care, and other service systems.

3. Ensure functional capacity and eligibility reforms are tested against participant outcomes Relevant provision: Schedule 1, Parts 1, 8 and 9 (Functional Capacity, Permanence and Eligibility)

As a provider supporting people across a broad range of needs, genU’s experience is that participant needs do not always fit neatly within standardised frameworks.

genU recommends assessment methodologies should be tested and independently evaluated before implementation, with particular attention to participants who rely on intensive supports, including SIL.

genU also recommends that reforms include post-implementation review processes that assess their impact on participant access and outcomes, quality of support, safety and continuity of services.

4. Require transparent and evidence-based pricing arrangements that reflect the real cost of support delivery

Relevant provision: Schedule 3, Part 1 (Pricing Determinations)

Pricing decisions should be informed by transparent, independently validated data that reflects the genuine delivery of sustainable disability supports.

The requirements should include:

• publication of pricing methodologies and supporting evidence

• provider cost data to inform annual pricing reviews

• pricing arrangements that recognise workforce, supervision, compliance and service delivery costs

• consultation with affected providers before significant pricing changes

• pricing settings that support continuity of supports for participants with complex and high support needs.

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Submission 2534

Pricing reforms should be considered as part of the broader changes across the Scheme, including funding reforms, commissioning arrangements and regulatory obligations on providers.

5. Improve transparency of decision-making and impact assessment Relevant provisions: whole of Bill

There should be greater transparency around the evidence, modelling and assumptions used to inform major changes to participant funding, eligibility settings and pricing arrangements.

Where reforms may affect participant supports or service delivery, genU recommends the NDIA publish on its website supporting impact analysis, implementation assumptions and the evidence used to inform those decisions, including:

• participant safety and outcomes
• continuity of supports
• workforce impacts
• provider sustainability
• service availability in regional and rural communities. Greater transparency will help ensure these reforms are informed by practical service delivery realities and reduce the risk of unintended consequences across the support system.

6. Monitor participant safety, service continuity and provider sustainability throughout implementation

Relevant provision: Schedule 5 (Transitional Arrangements)

To ensure the scale and pace of the reforms under the Bill does not have unintended consequences, implementation should be accompanied by ongoing monitoring of participant, provider and service impacts.

genU recommends an established evaluation framework to monitor:

• participant safety and outcomes
• continuity of supports
• impacts on SIL services
• workforce availability, capability and retention
• provider sustainability
• service access in regional and rural communities
• potential impacts to health, housing, aged care, and other service systems. Findings should be reviewed at key implementation milestones and used to inform subsequent stages of reforms. This will provide an opportunity to identify emerging risks and ensure implementation can be refined before impacts are felt by participants, families and frontline services.

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