Submission 270 — Rise Wellbeing (270.3 Supplementary to submission 270) — NDIS Future Generations Bill | External submission

Submission to the Senate Community Affairs Committee

Regarding the National Disability Insurance Scheme Amendment (Securing the

NDIS for Future Generations) Bill 2026

Submitted by a Small Independent Support Coordination Provider, Rise wellbeing

Pty ltd

We are a small, purpose-driven Support Coordination provider that has dedicated years to supporting NDIS participants with complex disabilities, psychosocial disabilities, autism, trauma histories, intellectual disabilities, and multiple co-occurring conditions.

Our organisation was built on the values that originally underpinned the NDIS: choice, control, dignity, inclusion, and individualised support. We work closely with participants, families, carers, allied health professionals, and service providers to ensure participants remain safe, connected, and able to access the supports they require to live meaningful lives. We very often have to work for free, as we will never leave a participant unsupported and vulnerable…even when planners and delegates see ﬁt to remove funding and leave people and our business suffering.

While we support genuine efforts to strengthen the integrity and sustainability of the NDIS, we hold serious concerns that several proposed legislative changes risk creating unintended harm for participants while signiﬁcantly compromising the viability of small providers who deliver essential frontline services.

Many of the participants we support are already experiencing reductions in services, increased barriers to accessing supports, delays in decision-making, and heightened distress due to ongoing reforms. We believe these proposed changes may further disadvantage vulnerable Australians and weaken the safeguards that currently protect them.

Proposed Removal of Individualised Support Coordination Funding and

Introduction of Commissioned Support Coordination Services

The proposal that from July 2028 participants will no longer receive Support Coordination funding within their individual plans and instead access government commissioned providers raises signiﬁcant concerns.

Support Coordinators are not simply administrative workers.

We provide:

Crisis prevention and intervention.
Safeguarding and risk monitoring.
Service navigation.
Capacity building.
Advocacy.
Coordination across complex systems including health, housing, justice, education and mental health services.
Monitoring of provider quality and participant wellbeing. Many participants choose small providers because they value trust, consistency, cultural understanding, trauma-informed practice and personalised support.

The proposed commissioning model risks:

Reducing participant choice and control.
Creating monopolised service structures.
Limiting access to local providers with established relationships.
Removing participant autonomy in selecting who supports them.
Disrupting long-term therapeutic and support relationships. For participants with psychosocial disability, autism, intellectual disability, trauma backgrounds or communication barriers, the loss of a trusted Support Coordinator can be devastating and destabilising.

We have built our business and sustained the ongoing increases in costs for superannuation, work cover and all additional staffing costs because we are passionate about providing the level of expertise and care only a small, connected team can do. We service over 200 participants and have been proudly registered as a provider about to go into our 4th audit. We have support coordinators with education in master’s degrees, nursing, social work, counselling and more. Gee they are so fantastic and I’m so proud of our team. They have had to absorb the stress of “navigation” proposals, lack of funding and working for free (which we have to absorb as a company), working to KPI’S and justifying every second they support a participant and all the while they go above and beyond in their professionalism and sharing of expertise. The reduction in funding to participants means they have to expand their case load, adding more stress but they

do it because they care and love their job. They see at the coal face the difference it makes to engagement for participants and goal attainment.

As a small provider, we have already seen larger well established support coordination providers close their doors because the price point and no increase for 5 years has become unsustainable for them, perhaps this has been a “smoking out” process by the NDIA to narrow the ﬁeld and send support coordination off to a handful of large companies who will manage through AI integration and call centres. I can guarantee participants will be compromised and lives will be lost. The narrative is already that large org’s will be better positioned to secure government contracts, resulting in the closure of many incredible and passionate providers, like us, who have developed expertise through years of direct participant engagement.

Ultimately, the NDIS was designed to move away from block-funded services provided by call centre supports and toward participant-directed supports. This proposal appears to reverse that principle.

Reduced Funding for Social, Civic and Community Participation Supports We are deeply concerned regarding the proposal to reduce social, civic and community participation budgets by 50% and capacity-building daily activity budgets by 10%.

These supports are often misunderstood as discretionary or non-essential.

For many participants, these supports are the difference between:

Community inclusion and social isolation.
Mental wellbeing and psychiatric deterioration.
Skill development and lifelong dependence.
Employment pathways and unemployment.
Participation and institutionalisation. Many of the individuals we support already experience:
Chronic loneliness.
Anxiety disorders.
Depression.
Autism-related social challenges.

Trauma-related avoidance.
Psychosocial disability. Reducing access to community participation does not remove the need for support. It merely shifts costs elsewhere into:
Mental health systems.
Hospitals.
Crisis services.
Carer burnout.
Emergency accommodation.
State-funded services. Preventative supports are often the most cost-effective supports.

The proposal risks undermining years of participant progress and recovery.

Tighter Criteria for Plan Reassessments The proposed restrictions on unscheduled reassessments are concerning.

Disability is not always predictable.

Many participants experience:

Sudden health deterioration.
Mental health crises.
Family breakdown.
Loss of informal supports.
Housing instability.
Hospital admissions.
Increased risk and vulnerability. Restricting reassessment opportunities will leave participants without adequate support during periods of signiﬁcant need.

The proposed 90-day timeframe for NDIA decisions may further prolong crises and place participants at risk while awaiting outcomes.)

Support Coordinators regularly witness situations where immediate adjustments to supports prevent hospitalisation, homelessness, family breakdown or safeguarding concerns.

The legislation should preserve ﬂexibility for participants whose circumstances change unexpectedly.

Functional Capacity Assessments and New Framework Planning We acknowledge the government’s goal of creating consistency in planning decisions. However, we are concerned about the proposed shift toward standardised support needs assessments and functional capacity-based planning processes.

Many disabilities, particularly psychosocial disabilities, autism, neurological conditions and trauma-related conditions, cannot be accurately understood through standardised assessment tools alone.

Participants are not data points.

Their support needs are inﬂuenced by:

Environmental factors.
Trauma histories.
Informal support availability.
Mental health ﬂuctuations.
Community access barriers.
Housing stability. A standardised assessment process risks overlooking the complexity of real-life functioning.

We urge Parliament to ensure that allied health evidence, participant voice, lived experience and contextual information remain central to planning decisions.

New Eligibility Requirements and Requirement to Exhaust Treatment Options We are particularly concerned regarding proposals requiring individuals to exhaust “all appropriate treatment options” before qualifying for NDIS access.

Many participants already face:

Long public health waiting lists.
Financial barriers to treatment.
Limited specialist availability in regional areas.
Complex conditions where treatment outcomes are uncertain. Access to healthcare in Australia is not equal.

Participants should not be excluded from disability supports because they cannot access or afford treatments that may theoretically exist.

This approach risks creating inequity and disproportionately impacting people experiencing disadvantage.

Impact on Small Providers and Market Diversity The proposed reforms place signiﬁcant pressure on small providers, like us through increased compliance obligations, registration requirements and future commissioning arrangements.

While quality and safeguarding are essential, there is a genuine risk that many small providers will become ﬁnancially unsustainable.

Small providers often deliver:

Flexible supports.
Rural and regional services.
Highly personalised service delivery.
Specialist disability expertise.
Strong community relationships. If these providers disappear, participants may be left with fewer choices and reduced access to personalised supports.

The NDIS market should not become a system where only large organisations can survive.

Consultation Concerns We are concerned by widespread feedback from participants, providers and advocates that consultation timeframes have been signiﬁcantly insufficient given the

scale of these reforms. The opportunity give feedback has not been inclusive of promoted in a disability informed way. No easy reads or easy to ﬁnd submission portal. No promotion to people with disability on ow to have a voice has been advertised.

Changes of this magnitude require meaningful engagement with:

Participants.
Families.
Carers.
Disability advocates.
Allied health professionals.
Support Coordinators.
Small and regional providers. The disability community must have adequate opportunity to contribute before decisions are ﬁnalised.

Recommendations

We respectfully request that Parliament:

Retain participant-directed Support Coordination funding and preserve participant choice and control.
Reconsider proposed reductions to social, civic and community participation supports.
Maintain accessible pathways for urgent plan reassessments.
Ensure functional capacity assessments remain reﬂective and inclusive of participant voice as well as utilise professional evidence.
Remove or substantially amend requirements that participants exhaust treatment options before eligibility.
Protect market diversity by supporting small and regional registered providers.
Extend consultation processes to allow genuine co-design with the disability community.
Undertake independent impact assessments on participant wellbeing before implementing signiﬁcant funding reductions.

Remove all other provisions of support from plan managers.

Conclusion

As a small provider, our concerns extend beyond the future of our organisation.

We are concerned for the participants who rely on us.

Every day we support people who face signiﬁcant barriers, vulnerability and complexity. We witness ﬁrsthand the positive outcomes that occur when participants have access to consistent supports, trusted relationships and genuine choice.

We urge Parliament to carefully consider the real-world impact these reforms may have on people with disability, their families, and the providers who work alongside them.

The sustainability of the NDIS is important. However, sustainability must not come at the cost of participant wellbeing, safety, dignity, inclusion and choice.

The NDIS was created to improve lives. Any reform should strengthen that commitment, not weaken it.

How to save money:

Eliminate self-managed…Did you know, a participant can access funding through the portal if under $500 and still not have to provide an invoice, unless audited??? WILD.
Longer plans with options to review with changing evidence. 5-year plans for a non-degenerative participant will save billions over that length of time in reporting and reviewing.
Conﬂict of interest; why it was ever deemed acceptable and eligible for anyone to register as a plan manager and well as hosting any other service provision is wild. All plan managers should be a stand-alone service provider.
Create a competitive licencing data base od builders for home modiﬁcations like the states do for dept of housing.
Monitor price gouging for equipment purchases under “NDIS” approved funding.

Safety: All providers of any NDIS support should have some form of registration. Even creating a registration card for support workers (any but mostly private support workers) standardised that for each year they need to hold the worker clearance, ﬁrst aid, police check and perform 10 hours of professional development. A $150 yearly registration would support hosting the compliance and would ensure participants are safe. As a support coordinator we are able to educate and monitor the delivery of supports from an private support worker, but there are so many ripping off the system operating in unsafe manners, inappropriate to be providing support and billing unethically from participants but NO ONE has a watchdog in place to over see this as the system allows it. Who is accountable here?
Lastly, I all ABN holders in Australia should have it mandated all invoices be submitted through a system such as XERO. So many abn holders create and invoice on a word doc, get paid and no tax compliance is registered in a system unless they nominate it at personal tax time. So much tax fraud is unchecked, and this country is allowing it. So instead, the most vulnerable are to be punished. So many easy ﬁxes could change so much.

Thankyou for allowing my submission. I am passionate about the NDIS and the good it has done and will continue to do. Please make informed choices based on participants wellbeing and quality of life.

Warm regards, Proud and passionate service provider of Support coordination and