Balancing sustainability with accessibility and person-centred practice (Individual advocacy) | External submission

Submission 270 - Supplementary Submission

Executive Summary

NDIS Reform Consultation Submission

Submitted by Director, Rise Wellbeing Pty Ltd

Introduction

I support the long-term sustainability of the National Disability Insurance Scheme (NDIS) and acknowledge the importance of accountability, safeguarding, fraud prevention, consistency, and responsible stewardship of public funding.

The observations contained within this submission are informed by almost four decades of experience working alongside people with disability, families, carers, service providers, and multidisciplinary teams across the disability sector.

While many of the proposed reforms seek to address genuine challenges facing the Scheme, I believe it is essential that reforms remain grounded in the lived realities of the people who rely upon the NDIS every day.

Throughout this submission I have sought to highlight the importance of balancing sustainability with accessibility, accountability with compassion, and consistency with genuine person-centred practice.

Key Themes

People Are Not Standardised

Disability does not occur in neat categories, and human functioning cannot always be accurately captured through standardised assessment frameworks, diagnostic labels, or brief interactions with unfamiliar assessors.

While consistency is important, equity does not necessarily mean identical supports. Participants with similar diagnoses or assessment outcomes may experience vastly different support needs, risks, environmental circumstances, informal support networks, and lived experiences.

Future planning systems must retain flexibility, professional judgement, participant voice, and recognition of individual circumstances.

Funding Must Be Accessible in Practice

A recurring concern throughout the proposed reforms is the distinction between funding being approved and funding being genuinely accessible when required.

Examples within the submission demonstrate situations where participants experienced lengthy delays accessing approved supports due to funding release structures, despite clear evidence of need.

Funding that exists on paper but cannot be accessed when required may not function as accessible funding in practice.

Prevention Has Value

Many successful disability supports are preventative in nature.

Submission 270 - Supplementary Submission

The value of support is not always reflected through measurable improvement. Sometimes success is reflected through stability, maintenance of functioning, prevention of deterioration, avoidance of hospitalisation, reduced safeguarding risks, improved quality of life, and preservation of dignity.

Prevention, maintenance, capacity building, and early intervention should remain central considerations within future planning and funding decisions.

Choice and Control Require Understanding

Meaningful choice and control require participants to understand how the Scheme operates, what funding has been approved, how supports may be used, and how decisions can be challenged or reviewed.

Many participants, families, carers, and nominees require support to navigate increasingly complex systems and administrative requirements.

Participant education, accessible information, and capacity building should be strengthened across the Scheme.

Compliance Should Be Disability-Informed

Fraud prevention and safeguarding are essential components of a sustainable Scheme.

However, compliance, information gathering, audit, and debt recovery processes should distinguish between deliberate fraud and circumstances involving disability-related barriers, cognitive impairment, psychosocial disability, executive functioning difficulties, trauma, coercion, vulnerability, or carer overwhelm.

Accessibility, procedural fairness, and disability-informed practice should remain central to compliance activities.

Relationships Matter

Trusted relationships play a significant role in participant outcomes.

Participants often rely upon family members, carers, advocates, support coordinators, recovery coaches, allied health professionals, support workers, and providers to translate funding into meaningful supports and outcomes.

Future reforms should recognise the importance of continuity, trust, relational understanding, and participant choice when considering workforce, market, planning, and funding reforms.

Sustainability Must Consider Broader Outcomes

The NDIS is not solely a funding program. It is also a social and economic participation framework.

Disability supports contribute to workforce participation, community inclusion, economic activity, family sustainability, and quality of life for people with disability and those who support them.

Long-term sustainability should consider both Scheme expenditure and the broader social and economic value generated through effective disability supports.

Conclusion

Submission 270 - Supplementary Submission

The strongest and most sustainable NDIS will not be one that focuses solely on reducing expenditure. It will be one that balances accountability with compassion, consistency with flexibility, efficiency with accessibility, and sustainability with genuine person-centred practice.

People with disability are not administrative transactions, assessment scores, or funding packages. They are citizens, family members, friends, neighbours, colleagues, and valued members of our community.

Future reforms should remain grounded in the principles that originally underpinned the NDIS: choice and control, inclusion, dignity, autonomy, individualised support, and recognition of the inherent value of every person with disability.

The full submission provides detailed observations, examples, and recommendations supporting these themes.

To whom it may concern,

I am a Director and Support Coordinator and business owner at Rise Wellbeing Pty Ltd. The views expressed within this submission are informed by almost four decades working within the disability sector in Victoria and I am also a trained Counsellor.

I am deeply concerned by many of the proposed legislative changes currently being put forward in relation to people with disability and their supports. The comments within this submission reflect my concerns regarding the direction these reforms may take the NDIS and the lives of the people who rely upon it.

Submission 270 - Supplementary Submission

I wholeheartedly agree that the NDIS cannot be everything to everyone. Public funding must be sustainable, accountable, and used responsibly. However, at its core, the NDIS was always intended to support people with disability to access the supports they need to live ordinary, meaningful lives within their communities.

Somewhere along the way, it feels as though parts of the conversation have become increasingly focused on systems, processes, and costs, while losing sight of what disability support looks like in everyday life.

For many people with disability, support is not about luxuries or excess. It is about having someone help them get out of bed, shower, dress, eat a meal, organise medications, attend appointments, buy groceries, manage daily tasks, or participate safely in their community. It may mean going to a café, attending the footy, catching up with friends, or simply leaving the house with dignity and confidence — things many Australians take for granted without a second thought.

For many people with disability, relying on support is not temporary. It is a lifelong reality.

Any time we speak about another human being in diminishing or purely transactional ways, we risk losing sight of their humanity. People with disability deserve dignity, respect, safety, autonomy, and to have their voices genuinely heard — because like every other Australian, they matter.

I am deeply troubled when supports that directly impact a person’s dignity, safety, wellbeing, participation, or quality of life are dismissed as not representing “value for money”. I expect better from a Scheme, and a Government, established to support Australians with disability.

By all means, pursue fraud, recover stolen funds, and strengthen accountability. Ethical providers, participants, families, and taxpayers all want that. However, I ask those considering these reforms to stop and genuinely reflect:

If these changes were being proposed for you, your child, your parent, your partner, or someone you loved, would you feel comfortable with strangers holding such significant power over your daily supports, your independence, your opportunities, and your quality of life? Would you feel comfortable knowing decisions about your needs could be made by someone who has never truly known you, your circumstances, or your lived reality?

Because disability can happen to any one of us at any time.

The comments within this submission are based upon 37 years of lived experience working alongside people with disability as both a provider and advocate. They are informed by professional experience, conversations with colleagues, and the lived experiences of the participants and families we support every day.

Above all else, they are grounded in a philosophy of placing the person at the centre of their own life and asking how we, as a society, scaffold support around their needs, choices, goals, strengths, and dignity, rather than expecting people to fit neatly within systems that can never fully capture the complexity of being human.

Director – Rise Wellbeing

Schedule 1 – Access and Planning Measures

Submission 270 - Supplementary Submission

Part 1 – Defining Functional Capacity

I acknowledge the intent behind developing a more consistent and evidence-based framework for determining substantially reduced functional capacity and access to the NDIS. Consistency and fairness in decision-making are important goals, particularly where individuals with similar disabilities may currently experience differing outcomes depending on geography, assessor experience, or available evidence.

However, I hold significant concerns regarding how functional capacity may ultimately be defined and assessed in practice.

Functional capacity is not a simple or static concept. Disability cannot always be accurately understood through narrow, standardised, or time-limited assessment processes alone. A person’s ability to function is influenced not only by diagnosis, but by the interaction between disability, mental health, environment, communication ability, informal supports, stress, trauma, safety risks, and the level of scaffolding surrounding them in everyday life.

Many people appear to be functioning adequately only because of the extensive formal and informal supports holding their lives together. Family members, carers, clinicians, support workers, and community networks often provide significant unseen scaffolding through prompting, emotional regulation, supervision, transport, appointment management, advocacy, crisis prevention, and daily living support. If these supports were reduced or removed, the person’s actual functional capacity may deteriorate rapidly.

It is also important to recognise the enormous role played by informal supports and unpaid carers. Many carers can only continue in their role because formal supports are helping sustain the broader family system around them.

This is particularly relevant for people living with psychosocial disability, intellectual disability, autism, acquired brain injury, cognitive impairment, neurological conditions, and fluctuating conditions. Many individuals may present relatively well during a structured assessment, particularly on a “good day,” while still experiencing substantial difficulty functioning safely, independently, and consistently across everyday life.

I am concerned that highly standardised or brief assessments may fail to capture:

fluctuating disability,
masking and compensation strategies,
cumulative fatigue and burnout,
psychosocial instability,
the impact of carer burnout,
and the level of support currently required to maintain safety and stability. A person attending an appointment well-presented, articulate, or regulated does not necessarily reflect their actual day-to-day functioning. Many people with disability have learned to mask distress, minimise difficulties, or overcompensate in unfamiliar environments. Others may lack insight into their support needs entirely.

It is also important to recognise that what assessors observe during a brief appointment may only be possible because of the extensive unseen work occurring behind the scenes beforehand. Family members, carers, and support people are often providing prompting, emotional regulation, preparation, supervision, reassurance, transport, behavioural support, and ongoing scaffolding simply to help the person attend and participate in the appointment itself.

Occupational Therapists and other appropriately qualified clinicians currently undertaking functional

Submission 270 - Supplementary Submission

assessments are trained not only to assess whether a person can complete a task, but how they complete it, what support is required, whether it can be sustained safely and repeatedly, and what may sit beneath the presentation observed during an assessment.

I am concerned that overly rigid or simplified frameworks may unintentionally disadvantage people whose disabilities are less visible, fluctuating, psychosocial, or heavily dependent on support systems already under strain.

Consistency is important. However, consistency should not come at the expense of clinical judgement, individual context, safety, or humanity.

Assessment processes must remain person-centred, clinically informed, and undertaken by appropriately qualified professionals with expertise relevant to the participant’s disability and support needs.

True equity is not achieved by reducing complexity to a checklist. True equity is achieved when systems are capable of understanding the complexity of human functioning in real-world contexts.

The system should not only assess how someone presents during an appointment. It must assess what it takes for that person to survive, participate, regulate, remain safe, and sustain functioning in everyday life.

Part 2 – Limit Unscheduled Plan Reassessments

I understand the intent behind tightening the criteria for unscheduled plan reassessments and reducing unnecessary administrative burden on the Scheme. It is reasonable to expect that reassessment processes occur where there has been a genuine and significant change in circumstances or support needs.

However, I hold serious concerns regarding the proposal that only participants, plan nominees, or guardians will be able to request an unscheduled reassessment.

In practice, many participants do not have the capacity, confidence, communication ability, executive functioning, informal supports, or system knowledge required to independently identify, articulate, and navigate a reassessment request process.

I support many participants who cannot independently navigate reassessment processes due to cognitive, psychosocial, intellectual, communication, or executive functioning barriers. Others simply do not have the informal supports, technology, or system knowledge required to manage the process alone. Some have ageing parents who are already overwhelmed by the complexity of the NDIS and find it increasingly difficult to understand and navigate what has become an extremely complicated system.

For many of these individuals, their Support Coordinator is the person helping identify when circumstances have significantly deteriorated, risks have escalated, supports are failing, housing is breaking down, carers are burning out, or current funding is no longer sufficient to maintain safety and stability.

Preventing Support Coordinators from initiating or meaningfully facilitating reassessment requests risks creating additional barriers for the very people the Scheme was designed to support. It also fails to recognise the practical reality of how the NDIS currently operates.

Submission 270 - Supplementary Submission

Support Coordinators are often the people observing increasing crisis presentations, escalating risk, tenancy instability, hospitalisation, safeguarding concerns, service breakdown, or participants falling through gaps in the system. These issues do not always emerge neatly during scheduled review periods.

It is also critical to acknowledge the significant role played by informal supports and unpaid carers throughout the NDIS system. Many families provide extraordinary levels of unpaid care, advocacy, supervision, transport, emotional support, coordination, and crisis management over many years, often at considerable personal, financial, and emotional cost.

Support Coordinators are frequently engaged at the point where carers are already exhausted, ageing, unwell, or struggling to continue managing increasingly complex support needs. When these informal supports begin to break down, the impact on the participant can be immediate and significant.

Restricting reassessment pathways without recognising the realities of carer burnout and informal support collapse risks creating situations where people are forced to deteriorate further before support systems respond.

There appears to be an assumption underpinning this proposal that unscheduled reassessments are routinely requested unnecessarily or irresponsibly. This does not reflect my experience working within the sector.

Unscheduled reassessments are generally pursued because circumstances have genuinely changed and current supports are no longer adequate. In reality, many providers are cautious about requesting reassessments due to the very real fear that participants may lose existing supports or have funding reduced during the process.

Contrary to some public narratives, Support Coordinators are not spending their days enthusiastically lodging reassessment requests for fun and administrative enrichment. Most are already managing significant complexity, escalating crises, and extensive unpaid work simply trying to keep people safe and supported within inadequate funding environments.

A person’s support needs can change rapidly due to psychosocial deterioration, housing breakdown, family violence, behavioural escalation, hospitalisation, carer illness, declining health, or the loss of informal supports. These circumstances do not always wait for the next scheduled review cycle.

I am particularly concerned about the cumulative impact this proposal may have on participants with psychosocial disability, people living alone, participants without strong advocacy, individuals experiencing homelessness or housing instability, and those with limited informal support networks.

The NDIS was designed to support people with disability to live safely, participate meaningfully, and receive reasonable and necessary supports in response to their actual needs and circumstances.

We have already seen situations where participants are placed at risk because funding exists within a plan, but the support required cannot be accessed in a timely way due to system barriers or processes that fail to respond to changing circumstances. This raises an important question: who ultimately holds responsibility when a person’s needs have clearly changed, but the system is unable to respond quickly enough?

If reassessment pathways are to become more restrictive, then the Scheme must equally accept responsibility for ensuring that participants experiencing significant changes in circumstances are responded to quickly, compassionately, and effectively.

Submission 270 - Supplementary Submission

People with disability should not be expected to deteriorate further simply because the system has become harder to navigate.

Part 3 – Strengthening the Link Between an Impairment and the Need for Support

I understand the intent behind clarifying that funded supports must arise directly from the impairment for which a participant met the access criteria for the NDIS. From a policy perspective, I acknowledge that the Government is seeking greater clarity, consistency, and sustainability regarding what supports fall within the responsibility of the Scheme.

However, I hold significant concerns regarding how this may operate in practice for people with complex and overlapping support needs.

People do not live in silos, and neither do disabilities.

A person’s functional capacity, independence, participation, safety, and support needs are rarely shaped by a single diagnosis in isolation. Functioning is influenced by the interaction of disability, mental and physical health, cognitive capacity, trauma, environment, informal supports, housing stability, communication, and other factors that affect daily life.

Many participants live with multiple diagnoses and complex presentations where impairments interact in ways that significantly increase functional impact.

In practice, a participant may qualify for the NDIS based on one primary impairment, while additional conditions that may not independently meet access criteria still have a substantial impact on their ability to function, regulate emotions, communicate, participate, remain safe, or live independently.

When these factors are ignored or artificially separated from planning discussions, support systems risk no longer reflecting the participant’s actual needs.

For example, a participant may meet access based on a physical disability while also living with trauma, psychosocial disability, cognitive impairment, chronic health conditions, autism, intellectual disability, or mental health challenges that significantly affect how they function day to day.

Likewise, support needs may change depending on the availability of informal supports, carer burnout, housing stability, communication barriers, environmental stressors, or changes in health and functioning. These factors directly affect a person’s ability to live safely and participate meaningfully in everyday life.

I am concerned that an overly narrow interpretation of supports “directly arising from an impairment” may create artificial distinctions that do not reflect the realities of disability or human functioning. It risks excluding supports that are clearly necessary simply because they do not fit neatly within administrative categories.

The reality is that people’s lives, functioning, and support needs are interconnected. Effective disability support requires consideration of the whole person, not just the diagnosis that initially opened the door to the Scheme.

The NDIS was never intended to separate human beings into isolated diagnostic boxes. It was intended to support people to live safely, function meaningfully, and participate as fully as possible in their communities.

Submission 270 - Supplementary Submission

I am also concerned that this approach may have unintended consequences for people living with degenerative disabilities. We are already seeing stepped-down approaches to funding in some longer term plans, despite the reality that many degenerative conditions require ongoing maintenance and, over time, increasing levels of support rather than less.

True person-centred practice recognises that impairments interact, circumstances change, and support needs do not always fit neatly within administrative categories.

Part 4 – Support Determinations

I hold significant concerns regarding the proposal to enable the Commonwealth Minister to make determinations to reduce funding for groups of supports, particularly social, civic, community participation, and capacity-building daily activity supports.

These supports are not optional extras. For many people with disability, they are the very supports that make it possible to leave the house, attend appointments, buy groceries, access community activities, maintain relationships, and participate in ordinary daily life. Without them, many people would become increasingly isolated, dependent, and excluded from the communities in which they live.

I am concerned that reducing or restricting these supports through broad Ministerial determinations risks moving away from individualised, person-centred decision-making and toward systems-level decisions that may not adequately reflect the realities of participants’ daily lives.

People with disability do not experience their lives through funding categories. Supports relating to community access, social participation, and daily activities are often the very things preventing isolation, mental health deterioration, family breakdown, crisis escalation, hospitalisation, homelessness, safeguarding concerns, and increased reliance on more intensive and expensive service systems.

Having worked within the disability sector for almost four decades, including during periods when institutional models of care were still operating—and having worked within one myself—I do not raise these concerns lightly.

One of the most significant shifts in disability reform has been recognising that people with disability have the right to live as visible, connected, participating members of their communities rather than existing in segregated or isolated environments.

While contemporary systems may no longer resemble the institutions of the past physically, we must be careful not to unintentionally recreate institutional outcomes through policies that reduce people’s ability to access community life, relationships, autonomy, and meaningful participation.

There is a genuine risk of creating institutional-style isolation within people’s own homes. A person can technically live in the community while still experiencing profound isolation and exclusion if they do not have the support required to safely access and participate in everyday life.

For many participants, social and community participation supports are not recreational luxuries. They are the supports that enable human connection, routine, confidence, skill development, emotional wellbeing, independence, and protection against profound social isolation.

This is particularly relevant for people living with psychosocial disability, autism, intellectual disability, acquired brain injury, behavioural support needs, and other disabilities where community access may not be safe or realistically achievable without support.

Submission 270 - Supplementary Submission

Many people may physically be able to leave their home, yet still require substantial support to do so safely, consistently, confidently, or without significant vulnerability and risk.

Without appropriate support, many individuals will simply stop participating.

I am also concerned that the impact of existing funding schedules is already being felt by many participants. We are seeing situations where people can access community supports for a period of time and then effectively have to stop participating because they cannot access the funding they already have within their plan until it becomes available again.

The reality is that community participation, skill development, social connection, and independence do not operate on a funding schedule. People do not stop needing support simply because the next funding period has not yet arrived. For some participants, this stop-start approach is already reducing opportunities to leave the house, maintain routines, participate in their communities, and sustain the gains they have worked hard to achieve.

There are also important safeguarding considerations that must not be overlooked. People with disability experience significantly higher rates of violence, abuse, neglect, exploitation, and victimisation than the broader population. For many participants, community access supports are not simply about recreation or social outings. They are also safeguarding supports that help people navigate environments safely, attend appointments, access services, maintain visibility within the community, reduce vulnerability, and participate with greater confidence and autonomy.

Many participants cannot safely or independently access the community without support. Some require support workers to attend appointments, access groceries, navigate transport, manage anxiety, regulate emotions, maintain social connections, or simply feel safe enough to leave their home.

Others require two support workers to safely participate in community activities due to behavioural, physical, psychosocial, communication, or safety-related needs. Community access can already be difficult to achieve within existing funding arrangements. I currently support two participants who require 2:1 staffing to safely leave their homes and engage in their communities. Reducing support hours further risks creating a situation where some participants are effectively unable to access their communities at all, not because they do not want to participate, but because the supports required to do so safely are no longer available. The result is not greater independence, but greater isolation.

Tasks that many Australians take for granted can require significant planning, support, courage, and scaffolding for a person living with disability.

Community participation supports often sustain not only the participant but the informal support system surrounding them. For many families, these supports provide the only opportunity for carers to attend appointments, work, support other family members, or simply recover from chronic exhaustion.

Families are not an unlimited resource, and the sustainability of the NDIS cannot rely indefinitely on unpaid carers absorbing gaps in formal support systems. When carers burn out, become unwell, age, or can no longer continue, the consequences are often immediate and significant for the participant, their family, and the broader service system.

I acknowledge there have been increasing public discussions regarding poor practices within parts of the disability support workforce. I do not condone these practices. People with disability deserve professional, engaged, person-centred support, and expectations regarding workforce quality should absolutely be upheld.

Submission 270 - Supplementary Submission

However, I do not believe reducing participant supports is the appropriate response to broader workforce capability issues.

If the Government is genuinely concerned about quality, safeguarding, misuse of supports, or poor workforce practices, then reforms should focus on workforce capability, supervision, training, qualification standards, safeguarding, accountability, and quality oversight.

Over many years, training expectations, supervision structures, and workforce requirements have progressively weakened. At the same time, the rapid expansion and marketisation of the sector has resulted in many people entering highly complex support roles with limited training, supervision, safeguarding knowledge, or understanding of disability support practice.

People with disability should not lose access to essential supports because broader workforce systems have been inadequately regulated or supported.

Informal supports should be recognised as valuable protective factors, not quietly relied upon as an invisible substitute for adequate formal support.

Social and community participation is not a luxury. For many participants, it is the difference between visibility and isolation, safety and vulnerability, inclusion and quiet exclusion.

A sustainable NDIS should strengthen inclusion, capability, participation, and quality support delivery — not increase isolation, reduce autonomy, or unintentionally confine people to their homes because community participation has become financially or administratively restricted.

Part 5 – Plan Renewal

I support the introduction of a legislated end date for participant plans and the automatic creation of renewed plans following reassessment.

Providing greater clarity regarding plan periods and renewal processes may help reduce confusion, administrative delays, and uncertainty for participants, families, providers, and Support Coordinators.

I also support improved clarity regarding the treatment of unspent funds between plan periods, provided participants are given appropriate information, transparency, and reasonable transition arrangements.

In practice, many participants and families already experience significant stress approaching reassessment and renewal periods, particularly where there are delays, uncertainty regarding continuity of supports, or concerns about funding reductions.

Increasingly, stories and experiences within the sector regarding reductions to plans, equipment, therapy, respite, and support levels have created significant anxiety. As a result, some participants are becoming reluctant to submit change of situation requests even when their circumstances have deteriorated, for fear of losing the supports they currently have.

While I support greater clarity and consistency within the renewal process, safeguards remain essential. Participants should not be disadvantaged by NDIA delays outside their control, continuity of critical supports should be maintained during transition periods, and people with complex needs should not be left without access to essential services while administrative processes are occurring.

Submission 270 - Supplementary Submission

For many participants, particularly those living with psychosocial disability, cognitive impairment, intellectual disability, communication barriers, or limited informal supports, navigating plan transitions can still be highly stressful and complex.

Any renewal framework should therefore continue to prioritise accessibility, continuity, transparency, and participant understanding.

Not all reform is inherently negative. Reforms that improve clarity, continuity, and administrative consistency without reducing participant safeguards should be welcomed.

Part 6 - Reasonable and necessary supports

I acknowledge the intent behind clarifying the factors that must be considered by the NDIA when determining what supports are reasonable and necessary to fund. Greater clarity and consistency in decision-making may assist participants, families, clinicians, providers, and planners to better understand how funding decisions are made.

I also acknowledge the importance of ensuring the long-term sustainability of the NDIS and the need for equitable decision-making across participants.

However, I hold significant concerns regarding the increasing narrowing, standardisation, and interpretation of what may ultimately be considered “reasonable and necessary” in practice.

The phrase “reasonable and necessary” has always sat at the centre of the NDIS. However, as reforms increasingly seek to define, standardise, and potentially restrict what this means, an important question emerges: reasonable and necessary according to whom?

It is also important to recognise that the threshold for meeting the reasonable and necessary criteria is already significant. Supports must satisfy multiple legislative requirements simultaneously, and failure to meet a single element may result in funding being declined, even where a support is clearly disability-related, preventative, beneficial, or likely to improve a participant’s quality of life and functioning.

For this reason, I am concerned by proposals that may further narrow or restrict the interpretation of reasonable and necessary supports. The challenge for many participants is not that the current threshold is too low, but that the application of the existing criteria can already be difficult to understand, predict, and consistently apply.

What may appear reasonable from an administrative or financial perspective can look very different when viewed through the lived reality of disability.

For many people living with disability, activities that others take for granted—attending appointments, managing daily tasks, accessing transport, maintaining relationships, regulating emotions under stress, or participating in community life—may require significant support, planning, prompting, supervision, communication assistance, environmental modification, or trusted support relationships simply to occur safely and consistently.

Submission 270 - Supplementary Submission

People do not live in silos, and neither do disabilities.

A person’s functioning, independence, safety, and participation are rarely shaped by a single diagnosis alone. Disability is influenced by the interaction of many factors, including health, communication, environment, informal supports, housing stability, psychosocial wellbeing, and life circumstances.

A support that may appear non-essential within a narrow funding framework may, in reality, be the very support preventing crisis, hospitalisation, homelessness, family breakdown, safeguarding concerns, social isolation, or long-term deterioration.

Preventing deterioration is a legitimate outcome.

Maintenance of functioning, stability, safety, participation, and wellbeing should not be viewed as lesser outcomes simply because they are harder to measure.

The absence of crisis does not mean the absence of need.

Invisible supports often prevent visible crises.

I have supported participants where the effectiveness of ongoing support is most evident in what is no longer occurring. One participant recently reflected that since engaging with their Psychosocial Recovery Coach, they have not required hospitalisation for their mental health. Prior to receiving this support, they were admitted several times each year. It has now been five years since their last hospital admission.

From a narrow funding perspective, it may appear that little has changed because a crisis is not occurring. In reality, the support is working exactly as intended. The outcome is stability, prevention, improved quality of life, and reduced reliance on more intensive and costly systems of care.

As discussed throughout this submission, many participants also rely on significant informal supports that are often invisible within funding decisions but critical to maintaining stability and safety. Families are not an unlimited resource, and the sustainability of the NDIS cannot rely indefinitely on unpaid carers absorbing gaps in formal support systems.

Person-centred support must remain at the heart of the NDIS.

One of the greatest strengths of disability reform over recent decades has been the movement away from rigid, one-size-fits-all approaches and toward recognising the individuality, autonomy, strengths, goals, and support needs of each person.

No two people experience disability in exactly the same way.

Two people may share the same diagnosis while having very different functional capacity, support systems, communication needs, risks, life experiences, and ability to participate safely and meaningfully within their community.

This is why overly rigid, standardised, or checklist-driven approaches carry significant risk.

The NDIS was intended to support people as individuals, not as diagnostic categories.

For one person, success may mean employment or study. For another, it may mean leaving the house safely once a week. For another, it may mean maintaining stability and avoiding hospitalisation. For another, it may simply mean connection, dignity, routine, participation, and quality of life.

Submission 270 - Supplementary Submission

I also acknowledge the proposal that the NDIA must consider Scheme sustainability and equity across participants, including participants with similar needs and circumstances.

However, equity should not be confused with uniformity.

People who appear similar on paper may experience very different support systems, communication barriers, risks, trauma histories, environmental stressors, and abilities to participate safely and sustainably in everyday life.

True equity does not always mean providing identical supports. It means recognising that people experience disability differently and may require different levels or types of support to achieve comparable outcomes.

There is also a risk that sustainability becomes interpreted primarily through the lens of short-term financial cost rather than long-term social, economic, and human outcomes.

Supports that maintain stability, reduce crisis, sustain carers, prevent deterioration, support community participation, and reduce safeguarding risks should be viewed as preventative investment rather than unnecessary expenditure.

A sustainable NDIS is not simply one that spends less. A sustainable NDIS is one that supports people effectively enough to reduce long-term crisis escalation, family breakdown, acute system reliance, and preventable harm.

Reasonableness cannot be assessed solely through the lens of short-term cost or simplified functional outputs. It must also consider dignity, participation, safeguarding, prevention, and the realities of living with disability in everyday life.

Human beings are not cookie-cutter templates, and disability support systems should not attempt to reduce them to one.

Part 7 – Plan Suspensions

I hold serious concerns regarding the proposal allowing the NDIA to suspend a participant’s plan where “reasonable attempts” have been made to contact the participant but no response, or no adequate response, has been received.

I am even more concerned by the proposal allowing a participant’s status to be revoked entirely where a plan has remained suspended for 90 days due to unsuccessful contact attempts.

In principle, I understand the importance of maintaining accurate participant engagement and ensuring Scheme resources are appropriately managed. However, this proposal appears to significantly underestimate the communication barriers, accessibility issues, and practical realities many NDIS participants experience every day.

The practical reality is that many participants do not reliably answer phone calls from blocked or “No Caller ID” numbers.

Support Coordinators across Australia often joke that we are some of the only people left who answer blocked calls because there is always a chance it may be the NDIA. While humorous on the surface, it reflects a genuine and longstanding communication issue within the system.

Submission 270 - Supplementary Submission

Many participants experience anxiety regarding phone calls, have communication or executive functioning difficulties, require support to engage with correspondence, or have been specifically educated to avoid unknown callers due to increasing scam activity. Many carers and family members follow the same advice.

Yet this proposal may unintentionally place vulnerable people in a position where they feel pressured to answer unidentified calls out of fear of losing access to their plans and supports. This creates a concerning contradiction between safeguarding principles and administrative expectations.

It is also important to recognise that many participants and carers are not continuously available to answer unexpected phone calls. People may be attending medical appointments, receiving personal care, managing behavioural support needs, working, caring for family members, or relying on others to assist with communication.

Many carers are already balancing significant caring responsibilities alongside employment, appointments, advocacy, and their own wellbeing. The inability to answer an unexpected phone call during work hours should not place a person with disability at risk of losing access to essential supports.

Despite this, the proposal appears to place responsibility solely on participants to remain continuously contactable within a communication system that is often inaccessible, inconsistent, and difficult to navigate.

I am deeply concerned that participants may lose access to essential supports not because they have disengaged from the Scheme, but because the Scheme has failed to communicate with them in a way that is accessible, identifiable, and responsive to disability-related barriers.

It is also important to note that many participants currently do not have direct contact details for planners, identifiable return contact pathways, continuity of contact staff, or reliable mechanisms to determine who has attempted to contact them.

I recently received an email from the NDIA advising that a case had been closed. At the time, I had two active Change of Situation requests lodged on behalf of participants.

The email contained no receipt number, participant identifier, reference number, or information allowing me to determine which request it related to.

When I contacted the NDIA seeking clarification, the staff member was unable to identify the matter from the email alone. There were no notes attached explaining which request had been closed, and no clear pathway to determine what decision had been made.

As a result, I was left uncertain as to whether the closure related to one of the Change of Situation requests, an equipment matter, or another participant issue entirely.

This has not been an isolated experience. Similar situations have occurred on multiple occasions for both myself and colleagues working within the sector.

While this may appear to be a relatively small administrative issue, it illustrates a broader concern. Participants, families, and providers cannot reasonably be expected to engage effectively with systems when communications do not contain sufficient information to identify the matter being discussed, the participant affected, or the actions required.

Submission 270 - Supplementary Submission

If trained Support Coordinators cannot identify what an NDIA communication is referring to, how can we reasonably expect participants living with psychosocial disability, intellectual disability, cognitive impairment, communication barriers, or ageing carers to navigate the same system?

Person-centred communication requires flexibility, accessibility, consistency, and genuine recognition of how disability affects engagement.

Human beings are not automated systems waiting beside a phone for an unknown caller.

For many participants, maintaining engagement with the NDIS already requires significant support from carers, Support Coordinators, Psychosocial Recovery Coaches, advocates, and service providers.

The proposal also risks disproportionately impacting people living with psychosocial disability, cognitive impairment, intellectual disability, trauma, homelessness, housing instability, social isolation, and limited informal supports. These are often the very participants most at risk if their plans and supports are suspended or revoked.

The issue requiring reform here is not participant willingness to engage. The issue is the accessibility and design of the communication systems themselves.

A genuinely person-centred system would provide identifiable contact pathways, accessible communication options, clear follow-up processes, and recognition of disability-related barriers before punitive action is considered.

This is not a complex or unreasonable expectation. It is basic accessible communication practice.

In its current form, I do not believe this proposal adequately reflects the realities of disability informed communication, accessibility, psychosocial complexity, or carer capacity.

Participants should not lose essential supports because the system designed to support them failed to communicate with them in an accessible, transparent, and disability-informed manner.

Part 8 – Tightening the Meaning of Permanence

I understand the intent behind clarifying the meaning of permanence within the NDIS Act and ensuring that access to the Scheme occurs where impairments are likely to be lifelong and where appropriate treatment options have been explored.

However, I hold significant concerns regarding how these proposed changes may operate in practice, particularly for people living with complex disability, cognitive impairment, psychosocial disability, acquired brain injury, intellectual disability, fluctuating conditions, multiple diagnoses, or limited capacity to independently engage in treatment pathways.

The proposal appears to assume that there is always a clear and universally agreed pathway for determining when “appropriate treatment” has occurred, what constitutes sufficient treatment, and when a person has effectively exhausted available intervention options.

In reality, disability, rehabilitation, recovery, psychosocial functioning, and therapeutic response are rarely this straightforward. Medicine and therapy do not operate through rigid formulas.

What constitutes appropriate treatment can vary significantly depending on the individual, their diagnosis, co-occurring conditions, communication ability, personal circumstances, and capacity to meaningfully engage in treatment itself.

Submission 270 - Supplementary Submission

I am also mindful that access to the NDIS is already a lengthy and challenging process for many individuals and families. In practice, many people spend years pursuing diagnoses, specialist assessments, therapies, reports, and appeals before ultimately gaining access to the Scheme. I have supported people who were declined multiple times despite significant and enduring disability before eventually meeting the required threshold.

This experience does not suggest a system where access is easily obtained. Rather, it highlights the complexity of disability, assessment, and eligibility determination, and the importance of ensuring that permanence and treatment requirements remain grounded in functional reality rather than theoretical treatment expectations.

It is also important to recognise that accessing diagnosis, treatment, and specialist assessment pathways is not always straightforward or affordable. As one example, I have considered pursuing an ADHD assessment myself and have been quoted costs exceeding $1,000. I am not seeking NDIS access in relation to this; however, the cost alone demonstrates that assessment and diagnostic pathways are not equally accessible to everyone.

The existence of a theoretical assessment or treatment pathway does not necessarily mean that pathway is genuinely accessible. Cost, availability, waiting lists, transport, cognitive capacity, executive functioning, and disability-related barriers can all affect a person’s ability to obtain diagnoses, engage in treatment, or produce the evidence required to satisfy eligibility processes.

I am also concerned that these reforms may unintentionally create unrealistic expectations regarding treatment participation and recovery, particularly for people who lack insight into their condition, cannot independently engage with therapies, have intellectual disability or acquired brain injury, or require extensive support simply to attend appointments consistently.

A participant may technically have access to therapies or treatment pathways, yet lack the functional capacity, emotional regulation, communication ability, support systems, transport, stability, or executive functioning required to meaningfully participate in them.

By way of example, I currently support a young participant with moderate to severe intellectual disability, Level 3 Autism Spectrum Disorder requiring very substantial support, severe ADHD, significant anxiety, and additional complex behavioural and psychosocial presentations.

The participant was also diagnosed with Bipolar Disorder. However, this condition was reportedly unable to be considered within NDIS eligibility discussions because the participant had not completed a standardised period of treatment and therapy associated with Bipolar Disorder.

The difficulty in this situation was that the participant’s existing cognitive impairment, intellectual disability, communication barriers, emotional regulation difficulties, and functional limitations significantly affected their capacity to meaningfully engage in the “standard” therapeutic approaches being referenced.

At the same time, the participant’s behavioural and support needs were escalating significantly, with existing Positive Behaviour Support funding becoming insufficient to safely respond to the level of complexity being experienced. Even though the treating psychiatrist explained this in a supportive letter, the diagnosis was dismissed and remains unacknowledged more than twelve months later.

This example highlights the risks of overly rigid interpretations of treatment participation, permanence, and functional capacity. The existence of a theoretically available treatment pathway does not necessarily mean a person has the practical ability, cognitive capacity, emotional regulation, or communication skills required to engage in that treatment effectively.

Submission 270 - Supplementary Submission

Without sufficient flexibility and clinical discretion, systems risk excluding or delaying essential supports for some of the very people most impacted by disability-related complexity.

I am also concerned about the potential for this proposal to unintentionally reinforce a narrow understanding of permanence.

Some disabilities are clearly lifelong and well understood as such. It is deeply concerning when people living with conditions such as Down syndrome are reportedly still being asked to repeatedly justify whether their disability is permanent in nature.

At the same time, permanence should not be interpreted in ways that discourage rehabilitation, therapy, recovery, or capacity building.

One of the strengths of the NDIS is that it supports people to develop skills, build capacity, increase independence, and achieve meaningful outcomes in their everyday lives. As providers, therapists, support workers, Support Coordinators, and Psychosocial Recovery Coaches, we are often actively working towards helping people require less support in specific areas over time.

If a participant learns to independently make a cup of tea, make their bed, catch public transport, manage part of their daily routine, or develop greater confidence navigating their community, this should be viewed as a success of the system.

It does not mean their disability is no longer permanent. It does not mean they no longer experience functional impairment. It does not mean they suddenly no longer require support in other areas of their lives.

Rather, it reflects the purpose of good disability support: helping people maximise their independence, participation, and quality of life wherever possible while recognising that many disabilities remain lifelong in nature.

Supporting people to build skills should never become evidence against them. It should be recognised as evidence that the supports are working.

Similarly, a person who experiences an acquired brain injury may require significant support during rehabilitation and recovery. With intensive therapy, rehabilitation, and appropriate supports over time, some individuals may experience substantial improvement in functioning and potentially reduce reliance on the Scheme in the future.

This should be viewed as a success of the system, not a reason to restrict early access to support.

Preventative and rehabilitative investment can improve long-term outcomes both for individuals and for Scheme sustainability.

The existence of potential improvement should not automatically negate the reality of current disability-related functional impairment and support need.

A person should not be required to prove that every conceivable treatment pathway has been exhausted before being considered eligible for essential disability supports.

There must remain room for clinical judgement, person-centred decision-making, treatment tolerability, participant capacity, co-occurring conditions, psychosocial complexity, and the practical realities of living with disability.

Submission 270 - Supplementary Submission

Without this flexibility, there is significant risk of creating systems that are overly rigid, inaccessible, and ultimately harmful to vulnerable people.

Part 9 – Eligibility Based on Access to Other Service Systems

I understand the intent behind clarifying eligibility where individuals are accessing, or eligible to access, supports through other service systems such as workers’ compensation schemes or motor vehicle accident schemes.

It is reasonable for the Government to seek clarity regarding scheme boundaries and to avoid situations where multiple systems are funding the same supports simultaneously.

However, I hold concerns regarding how this proposal may operate in practice, particularly where individuals technically remain connected to another scheme but are no longer receiving the supports required to maintain functioning, safety, independence, or quality of life.

In practice, eligibility within another system does not always equate to meaningful access to ongoing support.

I am concerned that an overly rigid interpretation of this proposal risks creating situations where participants fall between systems, with each system viewing the other as responsible while the person living with disability experiences reduced support, deterioration in functioning, and increased vulnerability.

By way of example, I currently support a participant who sustained significant injuries following a motor vehicle accident and was previously supported through the TAC system.

Over time, TAC ceased funding ongoing supports and effectively considered the active support component of the claim complete. However, the claim itself remained technically open in the event future accident-related issues emerged.

Despite the claim remaining open on paper, the participant was no longer receiving the practical supports required to maintain mobility, manage pain, sustain daily functioning, or participate safely and meaningfully in everyday life.

Without these supports, her mobility declines, pain increases, fatigue escalates, and her ability to safely manage her home and participate within the community is significantly reduced. With appropriate support, she is able to maintain stability, functioning, participation, and quality of life.

This example highlights an important distinction between theoretical eligibility for another scheme and actual access to practical support.

A participant should not be excluded from disability supports simply because another system remains technically attached to their history while no longer providing the supports required in reality.

People with disability should not bear the consequences of administrative boundaries, funding disputes, or uncertainty regarding which system should respond.

Person-centred decision-making requires consideration not only of whether another scheme exists, but whether the participant is genuinely receiving the supports they require to live safely, sustainably, and meaningfully within their community.

Submission 270 - Supplementary Submission

The focus should remain on actual functional impact, current support needs, continuity of support, safety, participation, and real-world access to services rather than purely on whether another scheme remains nominally connected to a participant.

Without this flexibility, there is a genuine risk of vulnerable people falling through gaps between systems, ultimately leading to deterioration in functioning, preventable hospitalisation, increased crisis presentations, and greater pressure on broader health and community services.

A sustainable and person-centred system should prioritise practical outcomes for the participant rather than relying solely on rigid jurisdictional boundaries between schemes.

Schedule 2 – Fraud Measures

Part 1 – Registration of NDIS Providers

I strongly support reforms that genuinely assist with reducing abuse, exploitation, fraud, neglect, and unsafe practices within the NDIS sector.

Participants who are vulnerable, isolated, cognitively impaired, psychosocially unwell, behaviourally vulnerable, or heavily reliant on others for support deserve strong safeguarding systems, quality oversight, and accountability.

There are unquestionably areas within the current NDIS market where stronger visibility, regulation, and enforcement are required. However, I believe there is also a significant opportunity for Government to strengthen the sector in a way that improves both safeguarding and workforce capability while still protecting participant choice, continuity of support, flexibility, and access to smaller providers.

I believe registration should operate through a tiered and proportionate model.

Large organisations, medium providers, small businesses, sole traders, and independent workers operate very differently and should not necessarily be subject to identical administrative burdens, costs, and compliance expectations. A scalable registration framework would allow providers to register at a level proportionate to the complexity, scale, and risk profile of the supports they provide.

I wholeheartedly believe all providers and workers delivering disability supports should hold appropriate screenings and clearances, follow the NDIS Code of Conduct, maintain safeguarding practices, and operate within clear professional expectations.

However, registration alone will not automatically create quality or safety.

Safeguarding vulnerable participants requires more than registration. It requires a workforce that is skilled, supervised, accountable, supported, trained, and genuinely person-centred.

I believe there is an enormous opportunity for Government to establish a formal registration and professional development framework for disability support workers and independent support providers. A system that combines registration, ongoing professional development, safeguarding training, supervision expectations, worker screening, and nationally consistent professional standards would represent a significant step forward for both participants and providers.

Submission 270 - Supplementary Submission

At present, there are many exceptional disability support workers operating within the sector. However, there are also workers entering highly complex roles with minimal training, inconsistent supervision, limited understanding of safeguarding responsibilities, and little exposure to structured disability practice frameworks.

This is not entirely the fault of workers themselves. Over time, workforce expectations, supervision structures, and qualification pathways within parts of the sector have progressively weakened. Many workers genuinely do not know what best practice looks like because nobody has formally taught them.

For example, the number of independent workers and sole traders who are unaware they should not administer medication—including over-the-counter medications such as Panadol—without appropriate medication administration training or delegation is concerning. This is not simply a compliance issue. It is a safeguarding issue.

There is also a genuine opportunity for the NDIS Quality and Safeguards Commission to develop nationally standardised governance templates, safeguarding tools, and operational resources.

At present, many small providers and sole traders are left trying to determine for themselves what documentation is required, what constitutes best practice, what auditors expect to see, and how to develop compliant governance systems. This creates inconsistency across the sector and places enormous administrative pressure on providers who are genuinely trying to deliver quality supports while navigating increasingly complex compliance requirements.

Nationally standardised resources relating to risk assessments, emergency planning, medication management, consent, incident reporting, safeguarding, and participant documentation would significantly improve consistency, workforce understanding, participant safety, and audit readiness across the sector.

There must also be consideration given to the significant financial and administrative burden associated with registration and audit compliance, particularly for small and medium providers.

As one example, our organisation’s upcoming audit costs are approximately $7,500 for a recurring audit cycle conducted every 18 months. While this may not appear significant to large organisations, it is a substantial amount of money for a small business.

The cost of compliance extends well beyond audit fees alone. Maintaining registration requires hundreds of hours of work developing and reviewing policies, governance systems, quality management frameworks, staff training processes, risk management systems, internal audits, evidence collection, and continuous improvement activities.

Much of this work is completed after hours and outside of billable service delivery. Small providers are often investing significant unpaid time simply to ensure they remain compliant, provide safe services, and meet the requirements necessary to remain registered and continue delivering supports to participants.

Our organisation currently supports approximately 200 participants. We willingly undertake this work because we believe participants deserve safe, high-quality, well-governed services and because best practice genuinely matters.

I want to be clear that I strongly support quality improvement, safeguarding, accountability, and robust governance systems. Good governance is not simply a compliance exercise. It protects participants, strengthens services, supports workers, and improves outcomes.

Submission 270 - Supplementary Submission

My concern is not with the existence of quality and compliance requirements themselves. Rather, it is ensuring that registration and compliance frameworks remain proportionate, sustainable, and achievable for ethical providers who are genuinely committed to delivering high-quality supports.

Without careful consideration, there is a real risk that increasing registration and audit burdens may unintentionally force smaller ethical providers out of the sector while larger organisations with greater administrative and financial capacity become increasingly dominant.

While this may appear efficient from an administrative perspective, it risks reducing genuine participant choice and control. Many participants actively choose smaller providers because they value relationship-based practice, continuity, responsiveness, flexibility, and being known as a person rather than a file or reference number.

It is also important to recognise that the size of an organisation is not, in itself, a measure of quality. Larger organisations may have greater financial resources and administrative capacity; however, this does not automatically translate into better participant outcomes, stronger relationships, or more person-centred support.

Smaller providers play an important role within the disability sector. They create local employment opportunities, contribute to community capacity, and often deliver highly individualised supports while still operating within professional standards, regulatory requirements, and quality frameworks.

A healthy NDIS market should include providers of different sizes and service models. Participants benefit when they can choose the provider that best aligns with their needs, preferences, culture, communication style, and support goals rather than being limited by market forces or compliance structures that inadvertently favour larger organisations.

It is also important to recognise that there are many ethical providers within the NDIS sector who are genuinely committed to participant wellbeing, safeguarding, quality service delivery, and responsible stewardship of public funding.

Our own organisation is one such provider.

During periods of continued rolled-over plans, our organisation identified multiple participants whose Support Coordination funding had accumulated beyond what was genuinely required to meet their needs at that time.

Rather than continuing to utilise funding unnecessarily simply because it was available, we proactively returned more than $80,000 in unused funding back to the Government.

Had we operated unethically, it would have been relatively easy to continue drawing down those funds. We chose not to because it was not clinically appropriate, ethically justified, or aligned with participant need.

I believe it is important that policy discussions surrounding fraud and compliance recognise that many providers are working extremely hard to operate ethically within increasingly complex systems.

One unintended consequence of increasing public narratives suggesting that all NDIS providers are exploiting the Scheme is the impact this is now having on ethical frontline workers.

I recently had a staff member tell me she no longer wants to openly say she works within the NDIS sector because she feels people now look at her differently when she explains what she does. She is an

Submission 270 - Supplementary Submission

exceptional Support Coordinator who works tirelessly supporting vulnerable people and hearing her feel embarrassed about working in disability support was genuinely heartbreaking.

The existence of fraud and exploitation within parts of the sector should absolutely be addressed. However, reforms must also avoid creating an environment where ethical providers become overburdened, financially strained, or viewed with blanket suspicion despite consistently demonstrating integrity and responsible practice.

Safety and choice should not be positioned as competing concepts. Participants deserve both.

There is an opportunity here not only to strengthen fraud prevention and safeguarding, but to genuinely professionalise and strengthen the disability workforce in a meaningful, sustainable, and supportive way.

Schedule 2 – Fraud Measures

Part 2 – Civil Penalties and Regulatory Powers

I understand and support the need for appropriate fraud prevention measures, stronger safeguarding systems, and improved regulatory oversight within the NDIS.

There have unquestionably been serious concerns regarding fraud, exploitation, organised criminal activity, inappropriate claiming practices, inflated pricing, and unsafe conduct within parts of the sector. Vulnerable participants deserve protection, and public funding should be used responsibly, transparently, and for the purpose it was intended.

I say this not only as a provider working within the sector, but also as a taxpayer and community member who wants to see NDIS funding protected and directed toward the supports, therapies, safeguards, staffing, equipment, and services that people with disability genuinely require to live safe, meaningful, and included lives.

Fraud, exploitation, intentional misuse of funding, and organised criminal behaviour within the Scheme should absolutely be identified and addressed. Every dollar lost to fraud is a dollar unavailable for participants who genuinely need support.

However, effective fraud prevention must remain balanced with procedural fairness, disability informed practice, participant safeguarding, accessibility, privacy, and practical understanding of the realities faced by participants and ethical providers within the Scheme.

There is a significant difference between deliberate fraud, organised exploitation, intentional misuse of funding, and good-faith mistakes made within an extraordinarily complicated service system.

These distinctions matter.

Many participants are expected to understand funding categories, service agreements, invoices, provider responsibilities, worker obligations, plan implementation, safeguarding, fraud risks, reporting pathways, and broader compliance expectations. They may be expected to do this while also living with intellectual disability, psychosocial disability, acquired brain injury, autism, cognitive impairment, trauma, communication barriers, executive functioning difficulties, or exhausted informal support systems.

Submission 270 - Supplementary Submission

In practice, many participants are sent out into the world with funding attached to their plans but very little structured education regarding how the system works, how to safely engage providers, how to identify poor practice, what responsibilities they hold, or how to protect themselves from exploitation.

While information may technically exist online, many participants require ongoing relational support, repetition, modelling, advocacy, and practical guidance to meaningfully understand and safely navigate the system.

Simply directing vulnerable participants toward websites, written documents, videos, or generic information resources does not necessarily create genuine understanding or capacity building. People forget information. Many require repeated explanation and practical support over time.

This is where quality Support Coordination can play an important safeguarding, educational, and preventative role within the NDIS.

Support Coordinators frequently assist participants to understand their plans, navigate service agreements, identify inappropriate conduct, understand invoices and budgets, recognise safeguarding concerns, reduce vulnerability to exploitation, strengthen decision-making, manage conflict, and understand reporting pathways.

This role is often overlooked within broader policy discussions. Rather than viewing Support Coordination purely as an administrative function, there is an opportunity to recognise it as an important safeguarding, education, and capacity-building support within an increasingly complex regulatory environment.

Good Support Coordination can reduce participant vulnerability, provider manipulation, inappropriate spending, system confusion, service breakdown, safeguarding risks, crisis escalation, and long-term system instability.

It is also important to recognise that not all inappropriate use of funding occurs within the context of organised fraud or malicious intent.

In some circumstances, poor decisions or inappropriate use of funding may occur in the context of poverty, desperation, coercion, financial abuse, cognitive impairment, psychosocial instability, trauma, social isolation, impaired judgement, or limited understanding of complex NDIS processes and responsibilities.

Some participants may also feel pressured to agree to services, invoices, recommendations, or arrangements they do not fully understand because they fear losing supports, damaging important relationships, disappointing providers, or being left without assistance. Others may simply trust the people around them and assume that what they are being asked to approve is appropriate.

These situations should not automatically be viewed through the same lens as deliberate fraud or intentional misuse of funding. They highlight the importance of safeguarding, participant education, supported decision-making, and understanding the power imbalances that can sometimes exist within service relationships.

This does not mean inappropriate conduct should be ignored. However, it does highlight the importance of identifying underlying vulnerability and implementing safeguarding responses that reduce the likelihood of ongoing harm or repeated misuse.

In some situations, participants may require increased support, education, oversight, or alternative plan management arrangements rather than purely punitive responses alone.

Submission 270 - Supplementary Submission

For example, where concerns exist regarding a participant’s capacity to safely self-manage funding, there may be value in considering graduated safeguarding approaches such as supported self management or plan management arrangements that maintain participant choice and control while introducing additional financial oversight and accountability.

This approach may help reduce vulnerability to exploitation, financial misuse, coercion, administrative confusion, and preventable compliance concerns, while still preserving participant autonomy and flexibility wherever possible.

At the same time, provider fraud and deliberate exploitation must be treated differently.

Where providers, businesses, or individuals knowingly exploit participants, manipulate the Scheme, inflate costs, submit inappropriate claims, engage in organised fraud, or deliberately misuse public funding, there should be strong regulatory consequences proportionate to their professional obligations and level of responsibility.

I also believe there should be greater examination of pricing inflation and market distortion occurring within parts of the disability sector itself.

Many participants, families, and providers have observed situations where the cost of goods, equipment, or services appears to increase significantly once identified as NDIS funded. This is particularly concerning where identical or substantially similar items are available within the general community market at considerably lower prices.

As providers, we have at times actively sought quotes or explored purchasing pathways outside explicitly identified NDIS pricing structures in an effort to obtain more reasonable and sustainable pricing outcomes for participants and public funding alike.

This is not about avoiding transparency. It is about attempting to ensure value for money, responsible stewardship of public resources, and making NDIS plans stretch as far as possible.

Fraud prevention and Scheme sustainability should not focus solely on participant and provider compliance. They should also examine broader systemic contributors to unnecessary cost escalation across the disability market.

Every dollar unnecessarily absorbed through inflated pricing is a dollar unavailable for direct participant supports, therapy, safeguarding, staffing, equipment, and meaningful capacity building.

I also believe there is an opportunity for stronger collaboration and information sharing between relevant government agencies involved in regulation, taxation, business registration, safeguarding, and compliance oversight.

Where serious fraudulent conduct, exploitation, or deliberate misuse of public funding has been identified, there should be clearer mechanisms preventing individuals from simply dissolving one business entity and re-entering the sector under a new company structure, ABN, or provider arrangement without appropriate scrutiny.

This is not about overregulation or assuming wrongdoing across the sector. It is about ensuring that individuals or entities found to have engaged in serious misconduct cannot easily circumvent accountability systems through administrative restructuring alone.

Improved collaboration between the NDIA, the NDIS Quality and Safeguards Commission, the Australian Taxation Office, ASIC, and other relevant regulatory bodies may assist in identifying

Submission 270 - Supplementary Submission

patterns of serious non-compliance, fraudulent activity, or repeated phoenix-style business practices where appropriate.

At the same time, these processes must remain proportionate, evidence-based, procedurally fair, respectful of privacy, and consistent with natural justice principles.

I also believe there are opportunities for stronger fraud prevention safeguards within the NDIS portal and payment systems themselves.

For example, it is reasonable to question why self-managed claims can currently be submitted and reimbursed without mandatory invoice or receipt documentation being uploaded at the point of claim.

Given the scale of public funding involved, the absence of mandatory supporting documentation creates unnecessary vulnerability within the system and increases opportunities for fraudulent claiming, inappropriate spending, accidental misuse, and reduced accountability.

Requiring supporting documentation such as invoices or receipts at the time of claim submission may represent a relatively simple but effective safeguard that strengthens accountability while still allowing participants to retain flexibility and control over their supports.

Strong safeguarding systems should not rely solely on reactive investigations after harm has occurred. They should also focus on designing systems that proactively reduce opportunities for misuse, confusion, exploitation, and preventable error.

I am also concerned about how expanded monitoring, and investigative powers may impact participants, carers, and plan nominees.

The proposal notes that the NDIA must undertake a risk assessment process before exercising regulatory powers in relation to a participant. I strongly support the inclusion of safeguards such as these. However, it is essential that these processes are genuinely disability-informed in practice.

Participants may experience investigations, information requests, audits, or compliance processes very differently from the general population. Some may struggle to understand requests, become overwhelmed, disengage due to anxiety, provide inconsistent information, fail to respond appropriately, or appear “non-compliant” due to disability-related barriers rather than intentional wrongdoing.

It is also important to recognise the significant role played by carers, family members, and plan nominees. Many are already managing substantial caring responsibilities alongside employment, appointments, advocacy, behavioural support needs, financial pressures, and their own health and wellbeing. Some are experiencing significant carer fatigue and burnout long before any compliance process begins.

It is also important to recognise that not all carers and nominees have strong digital literacy, access to technology, or the ability to easily respond to administrative requests. I continue to work with ageing carers who do not own a mobile phone, do not use computers, or have limited access to email and online systems. Others may be managing health conditions, disability, fatigue, or caring responsibilities of their own.

While requests for information may appear straightforward from an administrative perspective, responding to audits, investigations, compliance notices, or information requests can present significant challenges for some participants, carers, and nominees. These challenges are not theoretical and are already occurring in practice.

Submission 270 - Supplementary Submission

I have supported a participant whose family was given seven days to provide approximately fourteen months’ worth of documentation as part of an audit process. Through considerable effort and stress, they managed to gather and submit the requested information within the timeframe provided. The process significantly affected their wellbeing and sleep. The participant’s mother, who was responsible for collating and submitting the information, was 69 years old at the time.

Following completion of the audit, they received no outcome letter, no feedback, and no indication as to whether any concerns had been identified or whether the matter had been finalised.

While audits and investigations are an important part of safeguarding public funding, participant experience also matters. Clear communication, reasonable timeframes, accessible information, and appropriate follow-up should form part of any compliance process.

Others may have been manipulated, financially abused, coerced, or influenced by family members, providers, nominees, or other individuals around them.

Some participants may also feel pressured to agree to services, invoices, recommendations, or arrangements they do not fully understand because they fear losing supports, damaging important relationships, or being left without assistance. Others may simply trust the people around them and assume that what they are being asked to approve is appropriate.

This can be particularly relevant where there are significant power imbalances between participants and the people supporting them. Agreement should not always be assumed to indicate genuine understanding, informed consent, or freedom from influence.

Participants should not feel criminalised simply for being vulnerable.

In my experience, most participants, families, carers, and nominees are genuinely trying to comply with a system that is often complex and difficult to navigate. Where concerns arise, it is important to consider whether vulnerability, misunderstanding, coercion, limited capacity, or inadequate support may have contributed to the situation before assuming deliberate wrongdoing.

For some participants, carers, and nominees, engagement with investigations, audits, compliance requests, or formal information-gathering processes may be highly distressing, confusing, or destabilising.

Systems built entirely around suspicion risk damaging the very relationships that support participant safety, engagement, disclosure, and safeguarding.

Trust is an essential component of effective safeguarding.

Participants are more likely to disclose concerns, seek help, engage honestly, and participate safely within systems where they feel respected, informed, supported, and treated with dignity.

Information gathering within the disability sector also requires heightened sensitivity due to the deeply personal nature of disability-related information.

Disability-sector documentation often contains highly sensitive material relating to trauma, abuse histories, behavioural presentations, mental health, psychosocial functioning, cognitive capacity, safeguarding concerns, family conflict, medical information, and personal vulnerabilities.

Submission 270 - Supplementary Submission

Participants often disclose highly personal information within case notes, behavioural support documentation, therapy reports, risk assessments, incident reports, psychosocial histories, and support records.

Any expansion of regulatory powers, information sharing, investigative authority, or inter-agency collaboration must therefore remain mindful of participant rights, privacy obligations, informed consent processes, confidentiality principles, and the sensitive nature of disability-related information.

There should be clear transparency regarding what information may be accessed, by whom, for what purpose, under what authority, and what safeguards exist to protect participant privacy.

Strong safeguarding systems are important. However, systems that unintentionally create fear, distrust, retraumatisation, or excessive surveillance risk undermining the very participant safety and engagement outcomes they are attempting to strengthen.

The role of Government should not be solely punitive. It should also remain focused on education, prevention, safeguarding, support, system improvement, and maintaining trust within the disability sector.

Strong systems are not built through fear alone. They are built through accountability, transparency, fairness, collaboration, and genuine respect for the people the system exists to support.

Part 3 – Information Gathering Powers

I understand and support the need for appropriate information gathering powers where there are genuine concerns regarding fraud, exploitation, misuse of public funding, safeguarding risks, or serious non-compliance.

The NDIA and relevant regulatory bodies require access to information in order to investigate concerns, protect participants, identify misconduct, and ensure public funding is being used appropriately. Strong systems of oversight and accountability are important and should form part of a sustainable NDIS.

However, the existence of stronger information gathering powers should not reduce the importance of proportionality, procedural fairness, privacy, participant rights, and disability-informed practice.

Information gathering within the disability sector requires heightened sensitivity due to the deeply personal nature of the information often contained within participant records.

Disability-sector documentation frequently contains highly sensitive information relating to trauma, abuse histories, behavioural presentations, mental health, psychosocial functioning, cognitive capacity, safeguarding concerns, family conflict, medical information, and personal vulnerabilities.

Participants often disclose deeply personal information within case notes, behavioural support documentation, therapy reports, risk assessments, incident reports, psychosocial histories, and support records. These documents often contain information shared in circumstances where participants are seeking support, disclosing vulnerabilities, or discussing highly personal aspects of their lives.

Any expansion of information gathering, monitoring, investigative authority, or inter-agency information sharing should therefore remain consistent with Privacy Act obligations, confidentiality principles, procedural fairness, participant dignity, and informed consent processes wherever possible.

Submission 270 - Supplementary Submission

There should be clear transparency regarding what information may be collected, who may access it, the purposes for which it may be used, how long it may be retained, whether it may be shared with other agencies, and what safeguards exist to protect participant privacy.

Participants should also be appropriately informed and supported throughout these processes wherever possible. Many people with disability already experience systems as complex, confusing, and difficult to navigate. Transparency and accessible communication are therefore critical to maintaining confidence and trust.

It is also worth considering whether existing participant information is always being utilised as effectively as it could be. Participants and families are often required to obtain costly assessments, therapy reports, and functional evidence to support access, planning, reassessments, and funding decisions.

Where relevant information has already been provided, there may be opportunities to reduce duplication by making greater use of existing evidence before requesting additional documentation from participants, families, providers, or clinicians.

I also support appropriate information sharing between relevant government agencies where serious fraud, exploitation, criminal activity, or safeguarding concerns have been identified. Where public funding is being deliberately misused or participants are being harmed, agencies should be able to work collaboratively to investigate and respond effectively.

However, these arrangements should remain proportionate, evidence-based, procedurally fair, respectful of privacy legislation, and subject to appropriate oversight and safeguards.

Most participants, families, carers, nominees, and providers are not engaging in fraud or exploitation. They are simply trying to navigate an extraordinarily complex system as safely and responsibly as possible.

I believe it is important to acknowledge the broader impact current public narratives surrounding the NDIS are having on participants, carers, workers, and providers. Many increasingly report feeling scrutinised, distrusted, or viewed through the lens of suspicion rather than support, inclusion, and human dignity.

Fraud should absolutely be addressed. However, systems that unintentionally create fear, distrust, retraumatisation, or excessive surveillance risk undermining the very participant safety and engagement outcomes they are attempting to strengthen.

Strong systems are not built through fear alone. They are built through accountability, transparency, fairness, collaboration, and genuine respect for the people the system exists to support.

Part 4 – Retention of Records

I understand and support the importance of maintaining appropriate records relating to the payment and receipt of NDIS funding. Public funding should be transparent, accountable, and capable of being reviewed where concerns regarding misuse or fraud arise.

Submission 270 - Supplementary Submission

I recognise that providers already maintain a range of participant and service delivery records, including case notes, support records, incident records, risk assessments, consent documentation, service agreements, and other documentation required under existing legislation, professional obligations, and NDIS Practice Standards. Appropriate record retention is an important safeguard and supports continuity of care, accountability, quality improvement, and participant protection.

My concerns relate primarily to the practical implications of requiring participants, carers, nominees, and families to retain extensive financial and administrative records over long periods without appropriate supports or system safeguards in place.

However, I hold concerns regarding how these proposed record retention requirements may operate in practice for many participants, carers, and families already living with significant disability-related, cognitive, financial, and caregiving pressures.

Not all participants or carers have strong literacy, digital literacy, executive functioning capacity, administrative skills, or the practical ability to independently manage complex paperwork systems.

Many carers are already managing personal care, medications, behavioural support needs, appointments, advocacy, financial stress, and crisis management, often while emotionally exhausted and navigating highly complex systems.

In practice, many families are simply doing the best they can with the capacity and resources available to them. For some, “record keeping systems” may literally consist of paper invoices stored in shoeboxes because that is the only manageable system available.

This should not automatically be interpreted as fraud, dishonesty, or intentional non-compliance. Rather, it highlights the importance of ensuring administrative and compliance systems are genuinely accessible, practical, and disability-informed.

I also believe there are opportunities for the NDIA to strengthen accountability and safeguarding through improved system design. For example, requiring invoices or receipts to be uploaded directly within the portal at the time of claim submission may provide a far more practical safeguard than expecting vulnerable participants and carers to independently retain years of documentation.

Where systems can safely automate record retention, reduce duplication, and minimise administrative burden, this may improve both compliance outcomes and participant experience while strengthening accountability across the Scheme.

Part 5 – Reducing Claim Times

I generally support the proposal to reduce the timeframe for making claims for NDIS supports to within 90 days of service delivery.

Clearer and more timely claiming requirements may assist with accountability, financial oversight, fraud prevention, and improved visibility of participant budgets. In principle, it is reasonable to expect supports to be claimed within an appropriate timeframe rather than many months after services have occurred.

Within our own organisation, we already invoice regularly, generally weekly or fortnightly, so this proposed timeframe would not create significant operational difficulty for us directly.

Submission 270 - Supplementary Submission

Delayed invoicing can create significant confusion for participants, carers, providers, and plan managers, particularly when older invoices emerge after plan transitions or long delays. Participants and families may reasonably believe supports have already been claimed and accounted for within their available budgets, only to later discover substantial outstanding invoices still exist.

More timely claiming processes may therefore improve transparency, budgeting, financial predictability, and reduce administrative confusion across the Scheme.

At the same time, it is important to recognise that many claiming difficulties arise not from fraud or dishonesty, but from illness, caregiving overwhelm, inaccessible systems, delayed communication, or administrative complexity.

For example, I supported a self-managed participant whose mother fell behind in submitting claims for approximately one month due to her own health issues and caregiving responsibilities. During this period, the participant transitioned from PRODA to the PACE system without the family fully understanding that the new plan had commenced, claiming processes had changed, and access to the previous claiming system would immediately cease.

When the mother attempted to submit legitimate outstanding claims, she discovered she could no longer access the previous system, creating significant stress and financial confusion despite there being no fraudulent intent whatsoever.

Situations such as this highlight the importance of ensuring that increased administrative expectations are matched by equally reliable NDIA systems, communication, and transition processes.

I also believe that if improved forecasting and Scheme sustainability are key objectives underpinning these reforms, there must be ongoing examination of NDIA planning and review processes themselves.

Long-term forecasting is unlikely to remain accurate where plans continue rolling over for extended periods despite changed circumstances, altered support needs, underutilisation, overutilisation, or significant life changes.

More timely and responsive review processes may improve forecasting accuracy, utilisation data, and alignment between funded supports and actual participant need.

This is not an argument for reducing necessary supports. It is simply an acknowledgement that accurate forecasting relies upon accurate and responsive planning systems.

Overall, I support the intention of improving timeliness, accountability, and financial visibility across the Scheme. However, stronger compliance expectations should be accompanied by reliable systems, clear communication, accessible claiming processes, responsive review pathways, and practical safeguards for participants, carers, and providers navigating an already highly complex system.

Part 6 – Registered Plan Management Providers

I understand the rationale underpinning proposals to strengthen registration requirements for plan management providers and to potentially commission a panel of providers to deliver these services.

I appreciate the importance of accountability, consistency, safeguarding, fraud prevention, financial oversight, and ensuring participants have access to reliable and high-quality plan management services.

Submission 270 - Supplementary Submission

However, I hold concerns regarding the potential unintended consequences of moving toward a smaller commissioned panel of providers, particularly if this results in reduced participant choice, decreased market diversity, and the loss of relationship-based service models that many participants currently value.

Within the current system, there are many smaller plan management organisations providing highly personalised and responsive support to participants and families. Many have developed long-term trusted relationships with the people they support and play an important role in helping participants understand, navigate, and confidently utilise their NDIS funding.

For many participants, particularly those who experience anxiety, psychosocial disability, cognitive impairment, communication barriers, trauma, or difficulty navigating complex systems, the ability to speak with a familiar and trusted person matters enormously.

Many smaller plan management providers know their participants by name, understand their circumstances, communicate directly and accessibly, and provide a level of familiarity that can help participants feel safe asking questions, seeking clarification, and discussing concerns without fear of judgement.

This may appear to be a small thing, however for many participants and families it can make a significant difference to their confidence, understanding, and ability to effectively engage with the Scheme.

For many participants, plan managers also provide an important point of accessibility within an otherwise complex system.

While participants may have the name of their planner listed within their NDIS plan, direct access to decision-makers can often be limited. In practice, enquiries frequently need to be directed through general NDIA communication channels, with requests passed on internally before contact is made.

It is also important to recognise that participants do not necessarily have an ongoing relationship with a single planner throughout their NDIS journey. Staff changes are a normal part of any workforce and it is understandable that people move roles or leave organisations. However, participants are not always informed when these changes occur and may only become aware they have a new planner when a review or reassessment takes place.

For some participants and families, this can mean repeatedly explaining their circumstances, support needs, risks, goals, and personal history to new decision-makers. While records and reports provide important information, they do not always capture the full lived experience of the person or the context surrounding their supports.

By contrast, many smaller plan management providers offer direct and consistent points of contact. Participants often know who they are speaking with, feel comfortable reaching out when they have questions, and can access support from someone who understands their circumstances, communication needs, and funding arrangements.

While plan managers do not make funding decisions, these trusted relationships can play an important role in helping participants understand information, navigate the Scheme, and feel supported within what can often be a complex and overwhelming system.

I also believe the role of quality plan management is often underestimated within broader policy discussions.

Submission 270 - Supplementary Submission

Good plan managers do far more than simply process invoices or manage financial transactions. Many relationship-based plan managers quietly play an important role in participant education, safeguarding, financial oversight, system navigation, and practical capacity building.

Where trusted relationships exist, plan managers are often able to guide participants and families regarding what may or may not meet NDIS requirements, how budgets can be managed sustainably, and how to make informed decisions regarding funding utilisation.

Because these conversations occur within established and trusted relationships, participants and carers may feel more comfortable asking questions, seeking clarification, discussing concerns, and learning about the Scheme in a supportive and non-judgemental way.

This type of support can help reduce confusion, strengthen participant understanding, support informed decision-making, improve financial literacy, and reduce the likelihood of unintentional misuse of funding.

There is a significant difference between transactional invoice processing and relationship-based financial guidance delivered within a trusted support framework.

Quality plan management can therefore contribute not only to participant outcomes, but also to Scheme sustainability, participant safeguarding, fraud prevention, and improved financial accountability.

I am also concerned that commissioning arrangements may unintentionally favour larger corporate providers with greater financial resources, administrative capacity, and procurement experience, while smaller Australian-owned providers struggle to compete despite delivering high-quality and highly personalised services.

This is not an argument against larger providers. Many provide valuable services and play an important role within the sector. However, the size of an organisation is not, in itself, a measure of quality.

A healthy NDIS market should include providers of different sizes and service models. Participants benefit when they can choose the provider that best aligns with their needs, communication preferences, circumstances, and support goals.

I also hold concerns regarding payment timeliness and responsiveness within some larger plan management models. Delays in invoice processing can impact participants, providers, service continuity, small businesses, and support workers alike. Many smaller plan managers currently provide highly responsive communication and payment practices that support continuity of care and minimise administrative stress for participants and providers.

Strong governance and accountability are critically important. However, person-centred practice, participant choice and control, responsiveness, market diversity, and relationship-based support are also fundamental principles underpinning the NDIS.

Participants are not simply accounts to be processed through administrative systems. For many people with disability and their families, trusted relationships, responsive communication, and accessible support are essential components of safety, confidence, and effective navigation of the Scheme.

Any future commissioning or panel arrangements should therefore be designed in a way that preserves participant choice and control, supports market diversity, values relationship-based service

Submission 270 - Supplementary Submission

models, and recognises the important contribution that smaller providers continue to make within the disability sector.

Schedule 3 – Governance Arrangements

Part 1 – Decision-Making on Pricing

I understand the rationale underpinning proposals to centralise NDIS pricing decisions with the Commonwealth Minister while retaining the NDIA’s role in conducting independent analysis and stakeholder engagement through the Annual Pricing Review process.

I appreciate the importance of Scheme sustainability, financial accountability, pricing consistency, workforce planning, and ensuring public funding is used responsibly.

However, I hold concerns regarding the potential unintended consequences of moving final pricing decision-making authority into a more directly political and centralised process.

NDIS pricing decisions affect far more than provider profitability. They directly influence workforce sustainability, participant access to supports, service quality, provider viability, safeguarding capacity, continuity of care, and ultimately the lived experience of people with disability and their families.

I believe there is a risk that pricing decisions may become increasingly influenced by short-term budget pressures, political narratives, cost containment priorities, or public perceptions regarding the Scheme rather than the operational realities of delivering safe, ethical, and person-centred disability services.

There also needs to be greater recognition of the actual costs involved in delivering quality supports within the current NDIS environment.

While some NDIS hourly rates may appear generous in isolation, the practical reality for many providers is very different once the true costs of service delivery are considered. Providers must absorb the costs associated with wages, superannuation, leave entitlements, Workcover, portable long service, insurance, audits, registration, compliance systems, governance, supervision, staff training, incident management, information technology, administration, quality assurance, and significant amounts of non-billable labour.

Many ethical providers are not generating excessive profits. In reality, many operate on extremely modest margins while attempting to maintain workforce stability, participant safety, compliance obligations, and person-centred service delivery. Within our own organisation, despite maintaining strong governance practices and operating responsibly, we would consider ourselves fortunate to simply break even or achieve only a modest profit margin after operational costs are accounted for.

I believe this reality is often poorly understood within broader public and political discussions surrounding NDIS pricing.

I am also concerned about growing workforce instability and the gradual loss of experienced practitioners from the sector.

If pricing structures fail to adequately reflect the realities of supervision, training, safeguarding, governance, psychosocial complexity, and workforce development, there is a real risk of continuing to lose experienced workers across the disability sector. These skills take years to develop and cannot simply be replaced through workforce churn, rapid onboarding, or highly transactional service models.

Submission 270 - Supplementary Submission

The people most affected by workforce instability are ultimately people with disability and their families.

I am particularly concerned by ongoing narratives that appear to undervalue the role of Support Coordination and Psychosocial Recovery Coaching within the Scheme.

As reforms increase system complexity, compliance obligations, safeguarding requirements, administrative burden, and expectations regarding participant self-direction, the value of skilled Support Coordination and Psychosocial Recovery Coaching becomes increasingly important rather than less.

Navigating the NDIS is itself a functional support need for many participants.

For people living with psychosocial disability, cognitive impairment, intellectual disability, trauma, housing instability, safeguarding concerns, complex family dynamics, or involvement across multiple service systems, Support Coordination and Recovery Coaching often provide critical support in relation to crisis prevention, system navigation, capacity building, advocacy, safeguarding, risk management, service coordination, and continuity of support.

The preventative value of these supports can be difficult to quantify because success is often measured by what does not happen. The hospital admission that did not occur, the homelessness episode that was prevented, the family breakdown that was avoided, the mental health crisis that was de-escalated, or the safeguarding concern that was identified early may never appear in traditional performance measures. However, these outcomes remain critically important for both participants and the broader service system.

I also believe there needs to be broader recognition of the social and economic ripple effects that occur when relational, psychosocial, community participation, and capacity-building supports are reduced or undervalued.

Reducing supports does not necessarily reduce need. In many cases, it simply shifts the impact elsewhere across hospitals, mental health services, homelessness systems, emergency services, aged care, the justice system, families, carers, and other already stretched government services.

The cheapest service is not always the safest, most sustainable, or most person-centred service.

The disability sector also supports a significant workforce and contributes to local economies and communities across Australia. Decisions regarding pricing therefore affect not only providers, but also participants, families, carers, workers, small businesses, and broader community systems.

A sustainable NDIS should not focus solely on reducing expenditure. It should also consider workforce sustainability, participant outcomes, safeguarding, preventative value, carer wellbeing, economic participation, and the broader cross-government impacts that arise when supports are reduced without adequate alternative safeguards in place.

I also believe there are important governance considerations regarding the proposed shift in pricing decision-making authority.

While the NDIA may continue to undertake independent analysis and stakeholder consultation, there remains concern regarding what occurs if independent evidence and operational realities conflict with broader political or fiscal priorities.

Submission 270 - Supplementary Submission

Pricing decisions should remain transparent, evidence-based, consultative, operationally informed, and grounded in the realities of delivering quality disability supports safely and sustainably.

Strong governance is critically important. However, long-term Scheme sustainability also depends upon retaining ethical providers, skilled practitioners, experienced workers, and relationship-based supports within the sector.

A sustainable NDIS is not simply one that reduces expenditure. It is one that maintains a skilled, safe, experienced, supported, and person-centred workforce capable of supporting people with disability well into the future.

Schedule 3 – Governance Arrangements

Part 2 – Automation of Administrative Action

I understand the rationale underpinning proposals to allow the NDIA to automate certain administrative actions, including the processing of claims and payments.

There are aspects of automation that I can support. Where implemented appropriately, automation may assist with quicker processing, reduced administrative backlog, improved payment timeliness, and enhanced oversight of claiming activity. In principle, improving administrative efficiency within the Scheme is reasonable and understandable.

Where automation reduces delays, identifies anomalies requiring further review, or allows skilled staff to spend more time supporting participants rather than undertaking routine administrative tasks, it has the potential to deliver genuine benefits.

However, I believe there are also significant risks if automation begins to replace rather than support disability-informed human judgement and oversight.

Disability support systems are not purely transactional administrative systems. People with disability are not administrative transactions.

Many participants experience fluctuating capacity, communication barriers, cognitive challenges, trauma, psychosocial disability, literacy difficulties, or complex personal circumstances that do not always fit neatly within standardised administrative pathways.

Automation may work effectively for routine and low-risk administrative functions. However, many situations within the NDIS require contextual understanding, nuance, proportionality, trauma informed practice, and disability-informed human judgement.

I am also concerned about the potential loss of human interaction within systems that many participants already experience as confusing, impersonal, and difficult to navigate.

For many participants, navigating the NDIS is itself a functional support need.

We continue to support participants who do not own computers, struggle to use digital systems, rely upon paper-based communication, require assistance to understand correspondence, or become overwhelmed by administrative and technological processes. We also support ageing carers who have limited digital literacy and continue to rely upon face-to-face or telephone-based interactions to manage important aspects of daily life.

Submission 270 - Supplementary Submission

Automation should not unintentionally increase exclusion for participants and carers who already experience barriers relating to disability, literacy, communication, technology, trauma, ageing, or cognitive capacity.

I also believe there is significant risk if automated systems generate incorrect outcomes without accessible and responsive human review processes.

Automated errors can have very real consequences. Incorrectly delayed payments, rejected claims, debt notices, suspended supports, or automated compliance actions may result in service disruption, financial hardship, increased distress, safeguarding concerns, carer stress, or deterioration in participant wellbeing.

For some participants, particularly those already living with vulnerability or instability, even temporary interruptions to supports can have serious consequences.

I therefore strongly believe that automation should support, rather than replace, disability-informed human judgement.

Efficiency should enhance human-centred systems, not replace accessibility, procedural fairness, empathy, contextual assessment, or meaningful human oversight.

Participants should never feel powerless, unable to access a real person, or trapped within an automated process when attempting to resolve issues that may significantly impact their daily lives, supports, or funding.

There must be clear oversight mechanisms, transparent processes, accessible appeal pathways, timely human review options, and practical safeguards to ensure participants can easily seek clarification or challenge decisions that affect them.

Strong governance and efficient systems are important. However, the NDIS exists to support people, not processes.

Administrative efficiency has an important role to play within the Scheme, but long-term success will depend upon maintaining accessibility, procedural fairness, disability-informed practice, and meaningful human oversight alongside technological innovation.

Automation should strengthen human-centred systems, not replace them.

Schedule 4 – New Framework Planning

I understand the Government’s intention to improve consistency, transparency, sustainability, and equity within planning and funding decisions across the NDIS.

There have clearly been situations where participants with seemingly similar needs have received significantly different funding outcomes, and I acknowledge the importance of improving fairness and reducing unnecessary variability across the Scheme.

However, I also hold significant concern regarding the broader direction of framework planning reforms and the potential unintended consequences of moving too far toward highly standardised assessment and funding models.

Modern disability practice is built upon principles of person-centred support, individualised planning, choice and control, strengths-based practice, trauma-informed approaches, and recognition that

Submission 270 - Supplementary Submission

disability exists within the broader context of a person’s environment, relationships, supports, history, and lived experience.

People are not standardised.

Human functioning cannot always be accurately captured through assessment frameworks, rigid categories, funding templates, or brief interactions with unfamiliar assessors.

Two participants may share the same diagnosis, similar assessment scores, or similar functional classifications while experiencing vastly different support needs, risks, coping capacities, communication barriers, trauma histories, psychosocial complexity, environmental stressors, family circumstances, and day-to-day realities.

For example, two participants may both be diagnosed with Level 2 Autism Spectrum Disorder, yet function entirely differently depending on factors such as executive functioning capacity, trauma history, co-occurring conditions, emotional regulation, communication ability, informal supports, psychosocial wellbeing, cognitive profile, or safeguarding risks.

On paper they may appear similar.

In reality, their lives and support requirements may be completely different.

This means that a standardised package of supports, funding allocation, or assessment-based recommendation may work well for one participant while being entirely insufficient, inappropriate, or even harmful for another.

Consistency is important. However, consistency should not come at the expense of individuality, flexibility, professional judgement, or genuinely person-centred understanding.

Equity does not necessarily mean every participant with a similar diagnosis requires identical supports. True equity requires recognising and responding to the unique circumstances, strengths, risks, barriers, and support needs of each individual.

I also hold concern regarding proposals enabling rules to specify what information assessors must and must not consider during support needs assessments.

People do not live in silos. Disability and functional impairment rarely exist independently from trauma, psychosocial wellbeing, cognition, communication, executive functioning, environmental stressors, co-occurring conditions, family systems, physical health, behavioural complexity, or safeguarding concerns.

While I can appreciate attempts to focus planning more strongly on functional impact rather than diagnosis alone, I remain concerned about any system that attempts to artificially separate conditions, experiences, or circumstances that clearly influence how a person functions in everyday life.

The most accurate understanding of support needs comes from assessing the whole person and how they function in their real-world environment.

I also hold significant concern regarding any increased reliance on highly standardised assessment tools, short-form functional assessments, or framework-based evaluation models attempting to determine long-term support needs through limited interactions with unfamiliar assessors.

A four to six hour assessment is not truly “knowing” a person.

Submission 270 - Supplementary Submission

Many participants, particularly those living with autism, psychosocial disability, trauma histories, intellectual disability, acquired brain injury, communication difficulties, or fluctuating conditions may present very differently during a formal assessment than they do across their everyday lives.

Masking is also a very real issue.

A participant attending an assessment well-presented, articulate, engaged, or regulated does not necessarily reflect how they function day-to-day. Many people with disability have learned to mask distress, minimise difficulties, overcompensate, or present differently in unfamiliar environments. Others may lack insight into the extent of their support needs altogether.

It is also important to recognise that a participant’s presentation during an assessment may be heavily influenced by the significant support provided by family members, carers, or support networks leading up to the appointment. In some cases, considerable planning, prompting, emotional support, co-regulation, transport assistance, preparation, and recovery time may be required simply for the participant to attend and engage in the assessment process.

The effort required to successfully participate in an assessment is not always visible to the assessor. A participant appearing calm, organised, or engaged during a brief interaction should not automatically be interpreted as evidence that they function independently or experience the same level of stability across their everyday life.

A short assessment snapshot cannot always capture fluctuating functioning, trauma responses, emotional exhaustion, behavioural complexity, support reliance, psychosocial instability, safeguarding concerns, or the cumulative realities of living with disability over time.

The best outcomes for people with disability come from genuinely understanding the person and how they function in the real world. This understanding is often best informed through participant voice, family and carer perspectives, multidisciplinary input, longitudinal knowledge, and relational understanding developed over time.

It is also important to recognise that meaningful change often occurs gradually and may take considerable time to achieve.

For some participants, learning a seemingly simple skill such as making a cup of tea independently, making their bed, preparing a meal, using public transport, managing emotions more effectively, or participating more confidently in the community may take months or even years of consistent support, repetition, encouragement, and practice.

These achievements should not be dismissed simply because they do not occur quickly or because they may appear small when viewed through an assessment framework.

Small gains can have profound impacts on a person’s independence, dignity, confidence, safety, participation, and quality of life.

Framework planning models should be careful not to unintentionally prioritise short-term measurable outcomes over the long-term and often incremental nature of disability-related skill development, capacity building, maintenance, and participation.

I also believe there must be significant investment in disability-informed and trauma-informed training for planners, assessors, and decision-makers involved within future framework planning systems.

Submission 270 - Supplementary Submission

One of the concerns frequently raised by participants, families, and providers is that some decision makers appear to have limited practical understanding of the real-world impacts of complex disability and support needs.

I strongly believe the answer is not increasingly rigid assessment systems, but stronger disability informed practice, better training, improved professional capability, and genuinely person-centred planning processes.

I also hold significant concern regarding increasingly rigid funding schedules and staged funding arrangements.

Disability-related support needs do not occur in neat, predictable, or linear ways. In practice, staged funding arrangements can create significant barriers when supports cannot be accessed at the time they are genuinely required.

For example, we currently support a participant requiring multiple pieces of disability-related equipment, including a new wheelchair and a therapeutic bed. While Occupational Therapy funding had been approved within the participant’s plan, the funding was released in periodic funding schedules.

Before equipment could be recommended, trialled, assessed, justified, and appropriately prescribed, sufficient Occupational Therapy funding first needed to accumulate within the plan. In practice, this resulted in delays of more than nine months before enough funding became available to complete the required assessment and equipment prescription process.

During this period, the participant continued to live without equipment that had already been identified as necessary to support their mobility, comfort, independence, safety and daily functioning.

The issue was not that funding had been denied. The issue was that the participant could not access approved funding in a timeframe that reflected their actual needs.

This highlights an important distinction between funding being allocated and funding being genuinely accessible. Funding that exists on paper but cannot be utilised when required may not always function as accessible funding in practice.

While scheduled funding periods may be appropriate for some participants where there are demonstrated risks, safeguarding concerns, or specific financial management issues, I do not believe they should become the default approach for all participants regardless of their circumstances or support needs.

The same concern applies to Support Coordination and Psychosocial Recovery Coaching.

These supports are not solely focused on plan implementation. They involve capacity building, education, safeguarding, service coordination, multidisciplinary collaboration, crisis response, and assisting participants to navigate increasingly complex systems. For many participants, navigating the NDIS is itself a functional support need.

One of the intended functions of Support Coordination is to build a participant’s understanding, confidence, and capacity to engage with the NDIS over time. However, this becomes significantly more difficult when funding is exhausted within one funding period and unavailable for months afterwards despite ongoing implementation needs, emerging risks, changing circumstances, capacity building opportunities, or the need for timely multidisciplinary collaboration and problem-solving.

Submission 270 - Supplementary Submission

Participants may require intensive support due to housing instability, mental health deterioration, safeguarding concerns, service breakdown, family crisis, hospitalisation, or urgent changes in circumstances. Crisis does not occur according to quarterly funding schedules or administrative release periods.

Preventative support becomes extremely difficult when funding access itself becomes unstable.

I also hold concern regarding stronger “value for money” considerations where these may unintentionally create dehumanising interpretations of disability, support, therapy, or quality of life.

I have personally seen therapy funding reduced for a participant with intellectual disability because it was determined the intervention was “not value for money” due to perceived limitations in measurable improvement outcomes.

People with disability are not financial investment products to be assessed solely according to perceived productivity or narrow definitions of improvement.

For many participants, therapy, support, communication assistance, emotional regulation support, community participation, or maintenance-based interventions provide value through dignity, wellbeing, comfort, regulation, reduced distress, prevention of deterioration, improved relationships, and maintenance of existing functioning.

For some participants, maintaining quality of life and preventing decline may be just as important as measurable improvement.

At the heart of the NDIS was a commitment to move away from paternalistic disability models and toward person-centred practice, participant empowerment, individualised support, and genuine choice and control.

People with disability are the experts in their own lives. Participants themselves often best understand their challenges, strengths, aspirations, risks, support needs, and what is required for them to live safely, meaningfully, and with dignity. Equally, families, carers, advocates, and trusted support networks can provide valuable insight into a participant’s day-to-day functioning, support requirements, and lived experience, particularly where communication barriers, cognitive impairment, psychosocial disability, or fluctuating capacity may impact a person’s ability to fully articulate their needs.

Choice and control are not simply philosophical concepts. They are directly connected to autonomy, self-determination, safety, wellbeing, dignity, and quality of life.

I strongly believe future framework planning must remain grounded in person-centred practice, participant voice, disability-informed understanding, trauma-informed approaches, professional judgement, flexibility, relational understanding, and recognition that every person’s life and support needs are unique.

The value of a person should never be measured purely by how much “improvement” they are perceived capable of achieving.

Recommendations

Recommendation 1 – Preserve Person-Centred Planning

Submission 270 - Supplementary Submission

That framework planning, assessment processes, and decision-making models retain sufficient flexibility to recognise individual circumstances, strengths, risks, environmental factors, support networks, and lived experience, rather than relying solely on standardised assessment outcomes or diagnostic categories.

Recommendation 2 – Ensure Assessments Consider the Whole Person

That support needs assessments incorporate multidisciplinary evidence, participant voice, family and carer perspectives, longitudinal information, and real-world functioning, recognising that brief assessments may not fully capture the complexity of disability, fluctuating conditions, trauma, psychosocial factors, communication barriers, or support needs.

Recommendation 3 – Strengthen Disability-Informed Practice

That planners, assessors, decision-makers, and NDIA staff receive ongoing disability-informed and trauma-informed training to improve understanding of complex disability, psychosocial disability, autism, intellectual disability, communication needs, executive functioning challenges, and safeguarding considerations.

Recommendation 4 – Ensure Funding is Accessible in Practice

That approved funding remains genuinely accessible when required and that periodic funding schedules are applied only where there is a demonstrated need, rather than becoming a default approach across the Scheme.

Funding accessibility should be assessed not only by whether funding has been allocated, but by whether participants can reasonably access supports when they are needed.

Recommendation 5 – Recognise the Preventative Value of Supports

That planning and funding decisions recognise the value of prevention, maintenance, capacity building, safeguarding, early intervention, and crisis avoidance, including situations where successful outcomes are reflected through stability, maintained functioning, reduced risk, or prevention of deterioration rather than measurable improvement alone.

Recommendation 6 – Strengthen Participant Capacity Building and Education

That participants, families, carers, nominees, and support networks are provided with improved education and accessible information regarding:

 how the NDIS operates,  how plans can be used,  participant responsibilities,  funding flexibility,  change of circumstances processes,  review pathways,  safeguarding mechanisms,  and complaints processes.

Meaningful choice and control require participants to understand the system they are navigating.

Recommendation 7 – Adopt Disability-Informed Compliance and Fraud Responses

Submission 270 - Supplementary Submission

That compliance, information gathering, audit, debt recovery, and fraud prevention activities distinguish between:

 deliberate fraud,  exploitation,  misuse,

and:

 disability-related barriers,  cognitive impairment,  executive functioning difficulties,  psychosocial disability,  trauma,  literacy challenges,  coercion,  vulnerability,  or carer overwhelm.

Responses should remain proportionate, accessible, and person-centred.

Recommendation 8 – Improve Accessibility, Communication and Procedural Fairness

That communication, compliance processes, information requests, audit processes, review processes, and decision-making pathways are accessible, clearly communicated, disability-informed, and supported by meaningful opportunities for clarification, assistance, review, and human engagement.

Recommendation 9 – Support Workforce and Market Sustainability

That future reforms consider the sustainability of the disability workforce, the viability of quality providers, the importance of participant choice and control, and the value of maintaining a diverse market that includes both small and large providers.

Registration, pricing, compliance, and workforce reforms should balance accountability with practical sustainability.

Recommendation 10 – Ensure Automation Supports Human Decision-Making

That automation and technology are used to improve efficiency, timeliness, consistency, and oversight while preserving meaningful human review, professional judgement, accessibility, procedural fairness, and participant safeguards.

Automation should support people and systems, not replace disability-informed human decision making.

Recommendation 11 – Recognise the Broader Social and Economic Value of Disability

Supports

That future NDIS reforms consider not only Scheme expenditure but also the broader social and economic benefits generated through disability supports, including workforce participation, carer participation, community inclusion, economic activity, and improved quality of life for people with disability and their families.

Submission 270 - Supplementary Submission

Recommendation 12 – Strengthen Disability Workforce Capability and Professional

Standards

That consideration be given to the development of a nationally consistent disability workforce capability framework that supports ongoing professional development, supervision, competency maintenance, and workforce quality across the sector.

This may include the development of government-led practice resources, templates, guidance materials, minimum professional development expectations, and strengthened supervision requirements to support workforce capability while maintaining accessibility and workforce participation.

Any future workforce reforms should seek to improve quality, consistency, safeguarding, and participant outcomes without unnecessarily restricting participant choice and control or creating barriers for smaller providers delivering high-quality services.

Recommendation 13 – Improve Participant Access to Information and Decision-Making

That participants, families, carers, and nominees receive timely, accessible, and understandable information regarding decisions, reviews, audits, compliance activities, plan changes, and requests for information, including clear explanations of outcomes and available review pathways.

In Conclusion

I support the long-term sustainability of the NDIS and acknowledge the importance of accountability, safeguarding, fraud prevention, consistency, and responsible stewardship of public funding.

Many of the reforms proposed seek to address genuine challenges facing the Scheme, and I recognise the difficult task Government faces in balancing sustainability with the needs of people with disability, families, carers, providers, and the broader Australian community.

However, throughout this submission I have sought to highlight the importance of ensuring that reforms are assessed not only through financial and administrative lenses, but also through the lived realities of the people who rely upon the Scheme every day.

Disability does not occur in neat categories. Human lives are complex. People experience disability within the context of their families, relationships, environments, histories, strengths, challenges, aspirations, and support networks. Systems designed to support people must be capable of recognising this complexity.

Throughout my almost four decades working alongside people with disability, I have consistently seen the difference that appropriate support can make. Sometimes that difference is significant and highly visible. At other times it is found in the crisis that did not occur, the hospital admission that was prevented, the skill that took years to develop, the relationship that was maintained, the safeguarding concern identified early, or the dignity and quality of life preserved for a person who may never achieve traditional measures of independence.

Submission 270 - Supplementary Submission

I respectfully ask that future reforms remain grounded in the principles that originally underpinned the NDIS: choice and control, inclusion, dignity, autonomy, individualised support, and recognition of the inherent value of every person with disability.

People with disability are not administrative transactions, budget measures, assessment scores, or funding packages. They are citizens, family members, friends, neighbours, colleagues, and valued members of our community.

Any future NDIS must continue to place people at the centre of the system, rather than expecting people to fit neatly within the system itself.

The success of the NDIS also depends upon recognising the vital contributions of families, carers, advocates, support workers, allied health professionals, and providers who work alongside participants every day to help translate funding into meaningful outcomes, participation, safety, and quality of life.

I appreciate the opportunity to provide feedback regarding these proposed reforms.

The views expressed within this submission are informed by almost four decades of experience working alongside people with disability, families, carers, service providers, and multidisciplinary teams across the disability sector.

Should the Department, NDIA, Ministers, policymakers, or their representatives wish to discuss any of the issues, examples, observations, or recommendations raised within this submission further, I would be pleased to participate in those discussions and provide any additional information that may assist.

While I do not expect everyone will agree with every observation or recommendation contained within this submission, I hope it contributes constructively to ongoing discussions regarding the future direction of the NDIS and the experiences of the people who rely upon it every day.

Thank you for taking the time to consider this submission and the perspectives shared within it.