Submission 2573
Submission to the Senate Community Affairs
Legislation Committee
National Disability Insurance Scheme Amendment (Securing
the NDIS for Future Generations) Bill 2026
Introduction
I write this submission as the primary caregiver of two children with significant disability related support needs.
One of my children has severe autism and intellectual impairment. My other child presents with significant autism and ADHD-related functional impacts. Together, their support needs affect every aspect of daily life, including education, emotional regulation, sensory processing, communication, community participation, health care access, safety, transport, family functioning and my capacity to maintain employment.
I support the long-term sustainability of the National Disability Insurance Scheme.
However, I am deeply concerned that multiple provisions within the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 achieve sustainability not through systemic reform, but through the transfer of disability related responsibilities from government-funded supports onto unpaid family carers.
The Bill appears to proceed on the assumption that if the NDIS funds less, then mainstream services, communities, schools, health systems and informal supports will absorb the resulting gap.
For many families, including my own, those alternative systems do not currently exist in a form capable of doing so.
The greatest concern is therefore not any single amendment in isolation. It is the cumulative effect of multiple amendments operating together.
Taken together, the amendments create a legislative framework that narrows eligibility, narrows funded supports, increases reliance on informal care, restricts plan reassessments, limits flexibility and increases the role of sustainability considerations while simultaneously assuming the existence of alternative support systems that are already overwhelmed.
Lived Reality of Disability Caregiving
Much of the public discussion surrounding disability policy continues to underestimate the level of unpaid labour already performed by families.
Submission 2573
The support my children require extends far beyond ordinary parenting.
It includes:
behaviour regulation and crisis management emotional co-regulation sensory accommodation attendance at specialist appointments school advocacy educational planning transport to therapies and supports communication with providers implementation of therapeutic recommendations environmental modifications management of restrictive eating patterns administration of NDIS supports coordination of multiple service systems ongoing monitoring of safety and wellbeing
These tasks occur daily.
They are not optional.
They are not temporary.
They are disability-related supports being delivered by unpaid carers.
The Bill repeatedly assumes that families can absorb additional responsibilities.
For many families, there is simply no remaining capacity to absorb.
Part 1 – Defining Functional Capacity
The proposed definition of functional capacity is particularly concerning because it requires a person’s ability to be assessed without assistance from other people, assistive technology or modifications and in a context excluding environmental circumstances.
While this may appear objective, it risks creating an artificial assessment framework that does not reflect real life.
Children do not live in clinical testing environments.
They live in homes, schools and communities.
My children’s functioning is directly influenced by:
sensory environments
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school supports educational accommodations therapeutic intervention parental supervision environmental modification access to assistive strategies
Removing these factors from consideration may produce an assessment that bears little resemblance to how disability actually manifests in daily life.
For neurodevelopmental disabilities in particular, functioning is highly context dependent.
A child who appears capable in one environment may be entirely unable to cope in another.
The proposed framework risks underestimating support needs by treating disability as though it exists independently of environmental demands.
Part 2 – Limiting Unscheduled Plan Reassessments
The Bill proposes significantly tighter criteria for unscheduled plan reassessments.
This may be manageable for adults with relatively stable support needs.
It is far less appropriate for children.
Children experience rapid developmental change.
Needs can change significantly because of:
school transitions bullying puberty mental health deterioration increased behavioural distress loss of informal supports family breakdown housing instability emerging safety concerns
Children do not develop in straight lines.
Many neurodivergent children experience periods of significant regression, burnout or escalating support needs.
Restricting reassessments creates a real risk that plans become disconnected from reality.
Submission 2573
The likely result is delayed intervention, greater family stress and increased use of crisis services.
Early intervention is almost always cheaper than crisis intervention.
This amendment risks achieving short-term savings while generating higher long-term costs.
Part 3 – Strengthening the Link Between Impairment and
Supports
One of the most concerning provisions is the requirement that supports arise directly from an impairment.
Disability rarely operates in such a simple way.
My children’s needs do not fit neatly into isolated categories.
Autism affects communication.
Communication affects education.
Education affects emotional regulation.
Emotional regulation affects behaviour.
Behaviour affects community participation.
Community participation affects mental health.
Mental health affects family functioning.
The effects are interconnected.
The proposal risks creating endless disputes regarding whether a support arises directly from a particular impairment or from secondary consequences of that impairment.
Families may find themselves forced to prove causal links between disabilities and support needs that are obvious in practice but difficult to separate conceptually.
This is particularly problematic for children with multiple diagnoses or overlapping functional impairments.
Part 5 – Automatic Plan Renewal and Loss of Unspent Funds
Submission 2573
The proposal to automatically renew plans and prevent the carry-over of unspent funds creates significant concern.
The assumption appears to be that unspent funds indicate a lack of need.
This is often untrue.
In our family’s experience, accessing services has frequently been limited not by need but by availability.
Before my children were connected to appropriate providers, we spent extended periods on waitlists for allied health services.
This was not because services were unnecessary.
It was because services were unavailable.
Families regularly encounter:
workforce shortages closed books lengthy waitlists provider turnover cancellations geographic limitations insufficient specialist expertise
For children with autism and intellectual disability, finding suitably skilled providers can take months or years.
The inability to utilise funding during those periods should not be interpreted as evidence that support was unnecessary.
Removing carry-over provisions effectively penalises participants for failures within the service system itself.
No Available Safety Net Outside the NDIS
A major concern with this Bill is the assumption that support needs can simply be redirected elsewhere.
In practice, many families have already exhausted every available alternative.
Before obtaining support for my children, we joined waitlists across multiple allied health disciplines.
Like many Australian families, we experienced significant delays accessing:
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occupational therapy psychology speech pathology behavioural supports paediatric services
Many services were closed to new referrals.
Others had waitlists measured in months or years.
Some required substantial out-of-pocket costs beyond the reach of many families.
The Bill appears to assume that where the NDIS withdraws support, mainstream systems will step in.
There is little evidence that those systems currently have the capacity to do so.
Families cannot access services that do not exist.
Education Systems Cannot Absorb the Gap
The Bill repeatedly relies upon concepts of family, community and alternative service systems.
However, schools are already struggling to meet the needs of many neurodivergent students.
Parents routinely find themselves acting as:
behaviour specialists disability advocates educational coordinators case managers
Many schools lack:
specialist staff adequate training therapeutic supports behavioural expertise sufficient classroom resources
Yet the Bill imposes no corresponding obligations on education systems to absorb support needs that may no longer be funded through the NDIS.
The practical effect is that responsibility shifts to parents.
Not schools.
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Not governments.
Not service systems.
Parents.
Carer Burnout Is a Policy Risk
The Bill repeatedly refers to informal supports, family supports and parental responsibilities.
What it does not adequately acknowledge is that informal supports are not infinite.
Families have limits.
Carers experience:
physical exhaustion financial stress workforce exclusion social isolation relationship breakdown deteriorating mental health
The sustainability of the NDIS cannot be considered independently from the sustainability of carers.
If families collapse under the weight of unsupported care responsibilities, the resulting costs simply shift elsewhere.
Those costs emerge through:
emergency departments public mental health services child protection systems housing services welfare systems family violence services crisis accommodation
Reducing disability supports does not eliminate costs.
It merely changes where those costs appear.
The Risk of a Two-Tier Disability System
Submission 2573
The practical effect of these amendments may be the creation of a two-tier disability system.
Families with financial resources will continue purchasing supports privately.
Families without those resources will increasingly rely on already overwhelmed public systems.
Children’s outcomes should not depend upon parental income.
Yet this Bill risks widening existing inequalities by reducing access to supports while alternative systems remain inaccessible.
Recommendations
I respectfully recommend that the Committee:
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Reject provisions that expand reliance on unpaid parental care without corresponding reforms in education, health and community systems.
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Amend the Bill to recognise that disability-related parenting responsibilities can exceed ordinary parental expectations and remain eligible for funded support.
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Retain flexibility for unscheduled reassessments where children’s needs change.
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Retain mechanisms allowing unspent funds to carry over where provider shortages or waitlists prevent utilisation.
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Require independent modelling of downstream impacts on health, education, housing and child protection systems.
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Delay implementation of provisions that rely on alternative service systems until those systems demonstrate sufficient capacity to absorb demand.
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Conduct further consultation with families of children with autism, intellectual disability and other neurodevelopmental disabilities.
Conclusion
The sustainability of the NDIS is important.
However, sustainability should not be achieved by shifting disability-related support responsibilities onto families who are already operating beyond capacity.
The Bill repeatedly assumes that community systems, schools, health services and informal supports will absorb unmet need.
For many families, those systems are already unavailable, inaccessible or overwhelmed.
The result is not a transfer of support.
It is a transfer of burden.
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If governments wish to reduce reliance on the NDIS, they must first ensure alternative systems genuinely exist, are adequately funded, and are capable of meeting need.
Until that occurs, these amendments risk leaving children with disability and their families with nowhere else to turn.