National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
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: Jacquelene Rowell Director, CabemCare
Executive Summary
This submission is provided in response to the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.
My name is Jacquelene Rowell and I am the Director of CabemCare, an NDIS provider delivering Support Coordination and Psychosocial Recovery Coaching services to participants across Australia.
This submission supports the need for reform within the National Disability Insurance Scheme (NDIS), including:
• stronger fraud prevention measures • stronger provider regulation • improved safeguarding frameworks • stronger market oversight • improved workforce standards • improved operational consistency • reforms aimed at protecting the long-term sustainability of the Scheme.
There are genuine integrity concerns within the NDIS that require urgent attention.
These concerns include:
• fraudulent claiming • overservicing • misuse of line items • exploitative provider practices • weak market oversight • conflicts of interest • workforce capability concerns • poor safeguarding practices
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
• administrative inflation generated by system inconsistency.
This submission supports stronger compliance and regulatory powers where they are proportionate, transparent, and operationally targeted.
However, this submission also raises significant concerns regarding several provisions within the Bill, particularly where reforms appear heavily focused on participant-facing restriction mechanisms without corresponding improvement to internal system capability.
This submission argues that long-term sustainability cannot be achieved solely through:
• tighter reassessment thresholds • narrower access pathways • support reductions • automated decision-making expansion • assumptions regarding mainstream service availability.
The sustainability of the NDIS is also directly linked to:
• planning quality • implementation capability • workforce competency • provider accountability • safeguarding effectiveness • early intervention • consistency of evidence interpretation • reduction of duplicated administrative processes.
Across operational practice, many of the Scheme’s most expensive failures are not caused simply by participants receiving inappropriate supports.
They are also caused by:
• delayed intervention • inconsistent planning decisions • poor implementation • repeated reassessments • delayed assistive technology approvals • provider breakdown • workforce instability • crisis escalation • repeated evidence gathering • fragmented system responsibility.
This submission raises concerns regarding:
• the proposed definition of functional capacity under Schedule 1 Part 1 • restrictions on participant-requested reassessments under Schedule 1 Part 2 • support determination powers under Schedule 1 Part 4 • proposed changes regarding permanence and treatment under Schedule 1 Part 8
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
• assumptions regarding mainstream service availability under Schedule 1 Part 9 • expanded automation powers under Schedule 3.
This submission proposes that sustainable reform requires strengthening the Scheme from the inside out.
This includes:
• improving internal decision quality • strengthening provider regulation • reducing conflicts of interest • improving operational consistency • strengthening workforce capability • improving fraud detection systems • reducing duplicated administration • strengthening safeguarding responses • reducing implementation failure.
The long-term future of the NDIS depends not only on controlling expenditure growth, but on building a system that is:
• operationally capable • clinically informed • consistent • transparent • accountable • responsive to risk • proportionately regulated.
About the Author and Operational Context
My name is Jacquelene Rowell and I am the Director of CabemCare.
CabemCare provides Support Coordination and Psychosocial Recovery Coaching services to participants across Australia.
I work directly with participants experiencing a broad range of disabilities and complex support needs, including:
• psychosocial disability • autism • intellectual disability • neurological conditions • physical disability • trauma-related functional impairment • housing instability • social isolation.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
My role involves supporting participants through:
• access requests • Change of Circumstances applications • reassessments • plan implementation • assistive technology requests • safeguarding concerns • provider breakdowns • crisis responses • evidence gathering • Administrative Review Tribunal matters.
This submission is based on operational experience supporting participants navigating the NDIS system on a daily basis.
It reflects recurring issues observed across:
• planning processes • reassessment pathways • implementation failure • provider conduct • workforce capability • evidence interpretation • participant access to practical supports.
This submission is not opposed to reform.
The NDIS requires reform.
There are genuine integrity concerns within the Scheme that must be addressed.
However, reform must distinguish between:
• deliberate fraud • exploitative claiming • administrative inflation • poor operational capability • crisis-driven expenditure caused by delayed intervention.
These are not identical issues and should not be treated as though they require identical responses.
The central position of this submission is that long-term sustainability requires both:
• stronger regulation and • stronger internal capability.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
Without improving decision quality, implementation consistency, safeguarding capability, and workforce standards, there is a significant risk that participant-facing restrictions may increase downstream social and economic costs rather than reduce them.
Sustainability Measures Must Address Internal System Drivers
The Bill places significant emphasis on improving the long-term financial sustainability of the NDIS through measures including:
• tighter reassessment controls • support determinations • funding controls • changes to reasonable and necessary supports • functional capacity reforms • increased automation.
The objective of improving sustainability is both reasonable and necessary.
However, several provisions within the Bill appear heavily focused on restricting participant access pathways while giving comparatively limited attention to the internal operational failures that continue to drive avoidable long-term Scheme expenditure.
Across operational practice, many of the Scheme’s most expensive failures are linked not only to inappropriate claiming, but also to:
• delayed intervention • inconsistent planning quality • fragmented implementation • repeated reassessment cycles • delayed assistive technology provision • inconsistent evidence interpretation • workforce instability • lack of specialist expertise in complex disability matters.
These failures generate substantial administrative inflation across the Scheme.
Administrative inflation occurs where inconsistency and delayed decision-making create avoidable expenditure through:
• repeated reassessments • duplicated reports • repeated functional assessments • duplicated evidence gathering • appeals • provider turnover
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
• crisis escalation • emergency accommodation responses • preventable hospitalisation.
Participants with permanent and significant disability are frequently required to repeatedly reproduce evidence because reports, specialist recommendations, and functional impact information are interpreted inconsistently across planning and reassessment pathways.
This does not only create participant distress.
It also creates significant cost across:
• the NDIA • allied health systems • hospitals • review bodies • community services • provider networks • informal support systems.
The Bill introduces tighter reassessment controls under Schedule 1 Part 2.
While intended to reduce unnecessary reassessments and Scheme growth, restrictive reassessment thresholds may unintentionally increase long-term expenditure where participants remain trapped in plans that are technically approved but operationally unworkable.
Across operational practice, it is common for plans to appear adequate on paper while failing during implementation because:
• workforce assumptions do not reflect actual provider availability • regional participants cannot source services • psychosocial support needs fluctuate more rapidly than planning cycles allow • assistive technology repairs are delayed • providers withdraw from thin markets • informal supports collapse unexpectedly.
In many cases, the eventual cost of crisis response significantly exceeds the cost of timely preventative intervention.
For example, participants may spend months waiting for essential mobility equipment or repairs while providers, therapists, suppliers, and NDIA processes repeatedly exchange reports, quotations, reassessment requests, and additional evidence requirements.
During these delays participants may:
• lose mobility • become bedbound • lose community access • experience physical deterioration
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
• develop pressure injuries • lose informal support arrangements • experience significant mental health decline.
The cost of delayed intervention often extends far beyond the original support request.
A delayed mobility support may ultimately result in:
• hospital admission • increased support worker hours • carer burnout • housing instability • emergency intervention • long-term loss of independence.
Similarly, participants with psychosocial disability often experience fluctuating functional capacity that does not deteriorate in a neat or linear manner.
Restrictive reassessment pathways may unintentionally create circumstances where participants are required to deteriorate significantly before intervention thresholds are met.
This risks increasing:
• acute mental health presentations • homelessness • justice system involvement • crisis accommodation use • safeguarding concerns • involuntary treatment.
Long-term sustainability requires more than expenditure reduction.
It requires improving:
• decision quality • implementation consistency • operational capability • safeguarding responses • timeliness of intervention.
Recommendations
This submission recommends:
• specialist planning streams for complex disability categories • multidisciplinary consultation pathways in high-risk matters • national consistency audits regarding reassessment outcomes • mandatory written justification where specialist recommendations are declined • reduced duplicated evidence requirements for permanent disabilities
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
• escalation review pathways where essential assistive technology requests are delayed • safeguards ensuring reassessment restrictions do not prevent timely intervention • greater consideration of workforce shortages and regional service limitations during planning.
Functional Capacity and Access Reforms
Schedule 1 Part 1 introduces a formal definition of functional capacity and proposes that assessments be undertaken:
• without assistance from other people, assistive technology, or modifications; and • excluding, as far as possible, environmental and personal circumstances.
The objective of improving consistency in access decision-making is understandable.
There are legitimate concerns regarding inconsistent access outcomes and varying interpretation of evidence.
However, there is significant concern that the proposed approach risks oversimplifying the way disability impacts people in real-world environments.
Disability does not exist independently from:
• housing stability • trauma history • support systems • workforce availability • financial circumstances • regional access barriers • environmental stressors.
In operational practice, these factors frequently determine whether a participant can safely sustain daily functioning.
Attempting to isolate impairment from environment may create assessments that appear administratively consistent while failing to accurately reflect practical functional reality.
This concern is particularly significant for:
• psychosocial disability • autism • intellectual disability • trauma-related functional impairment • neurological conditions • participants heavily reliant on informal supports.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
Many participants are able to temporarily demonstrate capacity during structured assessments while being unable to sustain functioning safely within daily life.
This is especially common where participants:
• mask distress during assessments • overcompensate in formal settings • rely heavily on exhausted family members • function differently depending on environmental stressors • experience fluctuating psychosocial symptoms.
There is a significant difference between demonstrating isolated ability during assessment and sustaining safe independent functioning over time.
For example, a participant with psychosocial disability may present as articulate and organised during assessment while simultaneously being unable to:
• maintain housing • manage medication • regulate behaviour under stress • maintain nutrition • engage reliably with supports.
Similarly, a participant with physical disability may technically demonstrate movement in an assessment environment while living in inaccessible housing without transport access or workforce support.
In these situations, the environment is not separate from disability impact.
It is part of the participant’s functional reality.
There is also concern that the proposed framework may unintentionally create false independence.
False independence occurs where participants appear more functionally capable because:
• family members compensate heavily • supports prevent deterioration • assistive technology masks risk • participants temporarily perform beyond sustainable capacity.
Participants should not be disadvantaged because supports, therapy, or informal care prevented further deterioration.
Recommendations
This submission recommends:
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
• retaining environmental and personal circumstances as relevant considerations within functional assessments • stronger recognition of fluctuating disability • prioritisation of longitudinal evidence over snapshot assessment observations • safeguards ensuring participants are not disadvantaged because supports improved functioning • specialist mental health expertise within psychosocial disability assessments • greater operational guidance regarding masking and fluctuating presentation.
Restrictions on Participant-Requested Reassessments
Schedule 1 Part 2 introduces tighter controls on participant-requested reassessments, including requirements for significant and ongoing change.
The objective of reducing unnecessary reassessments is understandable.
However, there is concern that restrictive reassessment pathways may unintentionally create barriers for participants experiencing implementation failure, fluctuating psychosocial disability, or escalating safeguarding risk.
Across operational practice, participants frequently experience situations where:
• plans appear adequate administratively • funding technically exists • supports cannot be implemented safely in practice.
This may occur because:
• providers withdraw • workforce shortages escalate • family supports collapse • behavioural support needs increase rapidly • assistive technology fails • regional service availability changes unexpectedly.
These situations may not always fit neatly within rigid reassessment thresholds despite presenting substantial operational risk.
There is concern that participants may be required to deteriorate significantly before reassessment conditions are considered satisfied.
This is particularly concerning for participants with psychosocial disability, trauma-related impairment, or unstable housing.
In operational practice, deterioration may occur rapidly and may result in:
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
• homelessness • hospitalisation • safeguarding concerns • justice system involvement • crisis accommodation responses.
Restrictive reassessment pathways may unintentionally delay intervention until crisis thresholds are reached.
Recommendations
This submission recommends:
• emergency reassessment pathways for high-risk participant situations • recognition of implementation failure as valid grounds for reassessment consideration • rapid deterioration review pathways for psychosocial disability • escalation mechanisms where assistive technology delays create safety risks • safeguards ensuring reassessment restrictions do not prevent timely intervention.
Fraud, Overservicing, and Market Exploitation
This submission strongly supports stronger fraud prevention powers and stronger provider regulation.
Fraud within the NDIS is real.
Overservicing is real.
Market exploitation is real.
There are providers operating within the Scheme who should never have been permitted into high-risk support environments involving vulnerable participants.
However, there is concern that public discussion increasingly focuses on participant restriction while giving insufficient attention to the structural conditions that allowed exploitation to develop across parts of the provider market.
Across operational practice, recurring concerns include:
• inflated travel claiming • duplicate claiming • misuse of line items • excessive administration charging • unsupported service inflation
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
• poor record keeping • exploitative referral practices • providers discouraging participant choice and control.
There are also concerns regarding providers operating across multiple service streams simultaneously, including:
• support coordination • plan management • direct support work • SIL • transport • allied health.
This may create financial incentives linked to maintaining participant dependency and controlling multiple funding streams.
Participants with cognitive impairment, psychosocial disability, communication barriers, or trauma histories may be particularly vulnerable within these environments.
Many participants:
• do not understand NDIS pricing structures • do not understand line items • do not know how to identify inappropriate billing • fear losing supports if concerns are raised.
There are also operational concerns regarding:
• shell company arrangements • phoenix provider behaviour • layered subcontracting structures • invoice laundering through related business entities.
Importantly, fraud within the NDIS should not be treated as a single category.
There is a substantial difference between:
• deliberate organised fraud • exploitative overservicing • poor operational capability • administrative inflation • crisis-driven expenditure caused by delayed intervention.
These issues require different responses.
Registration alone will not resolve underlying issues within the provider market.
The issue is not simply registration status.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
The issue is:
• capability • accountability • operational oversight • safeguarding competency • enforcement.
Recommendations
This submission recommends:
• staged provider licensing requirements proportionate to participant risk • mandatory competency standards for high-risk support environments • stronger operational auditing frameworks • real-time fraud analytics identifying abnormal claiming patterns • monitoring of excessive travel charging and duplicate claiming • increased ownership transparency requirements • stronger investigative powers regarding shell company arrangements • faster intervention powers where participant risk is identified • stronger whistleblower protections.
Provider Capability and Safeguarding
The Bill introduces stronger registration and compliance mechanisms across the provider market.
This submission supports stronger safeguarding and workforce standards.
However, there is concern that registration alone may create an appearance of safety without addressing operational capability.
Some providers may appear compliant because:
• policies exist • audits are passed • documentation exists while significant capability gaps remain within actual service delivery.
This creates false professionalism.
The NDIS operates within environments involving:
• highly vulnerable participants • behavioural complexity • psychosocial disability
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
• trauma histories • restrictive practice risks • crisis escalation • housing instability.
Despite this, entry pathways into parts of the provider market remain disproportionately low relative to the complexity of the work being performed.
In operational practice it is not uncommon to encounter providers entering highly complex support environments with:
• minimal sector experience • poor understanding of legislation • limited safeguarding capability • limited understanding of psychosocial disability • poor incident management capability.
This creates substantial risk for participants.
The issue is not simply whether providers are registered.
The issue is whether providers are operationally capable of safely supporting vulnerable people.
There is also concern that compliance obligations are increasingly becoming administrative rather than operational in focus.
In practice, some providers may become highly skilled at producing documentation that satisfies audit requirements while remaining poorly equipped to safely manage complex participant environments.
The NDIS requires a regulatory framework that measures not only documentation compliance, but operational competence and safeguarding capability.
Recommendations
This submission recommends:
• minimum experience requirements before delivering complex supports independently • mandatory safeguarding and legislative training prior to provider approval • mandatory supervision requirements for new providers • specialist accreditation pathways for psychosocial disability and behavioural support • continuing professional development linked to provider approval • stronger operational auditing focused on real-world service delivery capability.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
Conflicts of Interest Within the NDIS Market
One of the most significant structural risks within the current NDIS market is the increasing concentration of multiple support functions within single provider ecosystems.
This includes situations where organisations simultaneously deliver:
• support coordination • plan management • direct support work • SIL • transport • allied health • behaviour support.
Integrated service models are not inherently inappropriate.
However, the structure of parts of the NDIS market creates financial incentives that may conflict with participant choice, independence, and genuine capacity building.
The original intent of the NDIS was to increase:
• participant choice • participant control • independence • market competition.
However, some market structures may financially reward:
• participant dependency • service concentration • reduced external oversight • internal referral retention.
Participants with psychosocial disability, cognitive impairment, communication barriers, or trauma histories may be particularly vulnerable within these environments.
Many participants rely heavily on providers to explain:
• their plans • their funding • their rights • their support options.
This creates substantial power imbalance.
Participants may fear losing supports if they question:
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
• invoices • reassessment recommendations • service quality • provider conduct.
This is particularly concerning where participants are heavily dependent on a single provider ecosystem for daily functioning or housing stability.
There are also concerns regarding referral practices where:
• participants are repeatedly referred internally without transparent discussion of alternatives • support coordinators experience pressure regarding preferred provider pathways • providers discourage external oversight.
This does not mean all integrated providers operate inappropriately.
In regional and thin markets, integrated service arrangements may exist because workforce availability is limited.
However, thin market realities should not prevent stronger safeguarding frameworks where conflicts of interest create elevated participant risk.
Recommendations
This submission recommends:
• stronger conflict-of-interest regulation across overlapping support streams • mandatory disclosure where providers operate across multiple participant funding categories • increased transparency regarding referral relationships and related entities • independent auditing of high-conflict provider structures • monitoring of abnormal cross-referral patterns • stronger safeguards where providers deliver both support coordination and direct supports • improved participant education regarding provider choice and conflict-of-interest risks.
Support Determinations and Cost Shifting
The Bill introduces support determination powers and funding reduction mechanisms intended to improve financial sustainability.
Improving sustainability is necessary.
However, reducing expenditure is not always the same as reducing cost.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
In practice, unsupported disability frequently shifts cost into:
• public hospitals • emergency departments • mental health systems • homelessness services • justice systems • aged care • crisis accommodation systems.
There is significant operational risk that broad funding restrictions may reduce visible NDIS expenditure while simultaneously increasing pressure across already overwhelmed mainstream systems.
This is particularly concerning where supports viewed administratively as non-essential are functioning as preventative interventions.
Across operational practice, relatively small supports frequently prevent:
• homelessness • hospitalisation • justice system involvement • behavioural escalation • carer collapse • social isolation.
For example:
• transport supports may prevent isolation and mental health deterioration • psychosocial support may prevent acute mental health presentations • support coordination may prevent housing collapse • assistive technology may prevent injury and increased dependency.
These supports may appear discretionary administratively while being highly cost-effective operationally.
The cost of delayed or restricted support is frequently absorbed elsewhere.
This is particularly concerning for participants with:
• psychosocial disability • unstable housing • behavioural support needs • limited informal supports • regional service barriers.
Long-term sustainability cannot be achieved by shifting unsupported disability into systems already operating beyond capacity.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
Recommendations
This submission recommends:
• participant impact assessments before broad funding reduction measures are implemented • mandatory consideration of downstream cross-system costs • safeguards for high-risk participants where support reductions may create elevated risk • stronger recognition of preventative supports within reasonable and necessary decision-making • transparent public modelling regarding downstream impacts of funding reduction measures.
Mainstream Service Assumptions and Cost Shifting
The Bill increases emphasis on determining whether supports are more appropriately delivered through mainstream systems.
Clarifying system boundaries is important.
However, there is concern that some reform approaches rely too heavily on theoretical system responsibility without adequately considering whether alternative systems are operationally capable of meeting participant needs in practice.
There is a substantial difference between:
• a service theoretically existing and • a participant being able to practically access safe and timely support.
Across operational practice, participants are frequently referred between systems where:
• the NDIS considers a support the responsibility of another system while • mainstream services consider the support disability-related.
This creates service refusal loops where participants remain unsupported despite significant functional impairment.
This is particularly common for participants experiencing:
• psychosocial disability • trauma-related impairment
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
• homelessness • justice involvement • behavioural complexity • dual diagnosis.
Operational realities currently include:
• excessive public mental health waitlists • housing shortages • regional absence of specialist services • workforce shortages • culturally unsafe service environments • limited behavioural support outside the NDIS.
A support pathway is not genuinely accessible simply because it exists administratively.
Practical accessibility must also consider:
• wait times • geographical access • workforce availability • cultural suitability • participant safety • communication accessibility.
Participants with psychosocial disability are particularly vulnerable because their needs frequently sit across:
• disability • mental health • housing • justice • behavioural support systems simultaneously.
When responsibility becomes fragmented across multiple systems without clear operational accountability, participants may ultimately receive no meaningful support from any system.
Recommendations
This submission recommends:
• mandatory consideration of practical accessibility before refusing supports on mainstream responsibility grounds • operational evidence that alternative systems are reasonably accessible before supports are refused • review rights where mainstream supports are unavailable in practice • stronger cross-system accountability between disability, health, housing, justice, and mental health systems • safeguards for participants experiencing repeated service refusal across systems.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
Automation and Automated Decision Making
Schedule 3 expands the use of automated decision-making processes within aspects of the NDIS administrative framework.
Automation may improve:
• administrative efficiency • workflow management • fraud analytics • duplicate claim detection • low-risk procedural processing.
However, there is significant concern regarding the use of automation within high-impact disability-related decisions involving:
• functional capacity • psychosocial disability • support determinations • participant safeguarding • behavioural complexity • fluctuating impairment.
Disability support decisions are not purely administrative decisions.
They are contextual human decisions involving:
• clinical interpretation • environmental realities • fluctuating functioning • trauma histories • implementation risk • safeguarding concerns.
There is concern that automation may create false consistency.
False consistency occurs where decisions appear operationally consistent because identical rules are repeatedly applied while underlying assumptions remain incomplete or disconnected from participant reality.
This risk is particularly significant for participants with psychosocial disability.
Participants may appear more stable within datasets because:
• family members compensate heavily
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
• supports mask deterioration • crises are prevented through informal intervention.
These realities are difficult to accurately capture through automated systems alone.
There are also concerns regarding transparency and procedural fairness.
Participants already frequently experience difficulty understanding:
• why decisions were made • how evidence was interpreted • why recommendations were declined.
Increased reliance on automated systems without sufficient transparency risks:
• reducing participant trust • increasing confusion • increasing appeals and review activity.
Automation should support human judgement, not replace it.
Recommendations
This submission recommends:
• mandatory human oversight for high-impact participant decisions • clear distinction between administrative automation and high-consequence participant decision-making • participant-accessible explanations for decisions involving automated processes • independent auditing of automated systems for bias or inconsistent outcomes • exclusion of complex psychosocial disability matters from fully automated decision- making.
Priority Recommendations
This submission recommends the following priority reforms:
- Establish specialist planning pathways for complex disability categories.
- Introduce stronger provider competency and safeguarding requirements.
- Implement operational auditing focused on real-world service delivery.
- Strengthen fraud detection and conflict-of-interest oversight.
- Reduce duplicated evidence requirements for permanent disabilities.
- Maintain rapid intervention pathways for high-risk participants.
- Improve consistency in evidence interpretation and planning outcomes.
- Require practical evidence of mainstream service accessibility before refusing supports.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
- Maintain human oversight for high-impact participant decisions.
- Strengthen workforce standards proportionate to participant vulnerability.
- Improve participant protections within integrated provider environments.
- Increase transparency regarding automated decision-making systems.
- Strengthen early intervention pathways to reduce crisis-driven expenditure.
- Improve cross-system accountability between disability, housing, health, and mental health systems.
- Ensure sustainability measures account for downstream social and economic impacts.
Conclusion
The NDIS is one of the most important social reforms in Australia’s history.
It has fundamentally changed the lives of many people with disability by increasing access to supports, improving independence, and creating opportunities that previously did not exist.
However, the Scheme is operating under increasing financial, operational, and regulatory pressure.
Reform is necessary.
Stronger safeguards are necessary.
Stronger provider regulation is necessary.
Improved fraud prevention is necessary.
This submission supports reforms aimed at protecting the long-term sustainability and integrity of the NDIS.
However, sustainability cannot be achieved solely through tighter participant restrictions or reduced access pathways.
Long-term sustainability depends equally on:
• improving decision quality • reducing administrative inconsistency • strengthening workforce capability • improving safeguarding responses • reducing conflicts of interest • improving implementation outcomes • intervening earlier to prevent crisis escalation.
Many of the most expensive failures within the NDIS occur not because participants receive too much support, but because systems fail to respond effectively early enough.
Participants should not carry the burden of structural failures within the Scheme itself.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 263
The future sustainability of the NDIS depends on building a system that is:
• more consistent • more accountable • more operationally capable • more clinically informed • more transparent • better regulated proportionate to participant vulnerability.
The NDIS must be strengthened from the inside out.
The success of these reforms should not be measured solely by reductions in expenditure growth.
They should also be measured by whether the Scheme becomes:
• safer • fairer • more consistent • more sustainable • more capable of supporting people with disability to live stable, independent, and dignified lives.
Submitted by:
Jacquelene Rowell Director CabemCare