NDIA Accountability Project

This project is in DRAFT

Concerns about NDIS reform sequencing in the Northern Territory (DRO advocacy)

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Submission 2746

1/18 Bauhinia Street

Nightcliff Community Centre, NT 0810

Ph: 08 8948 2246 admin@ntmhc.org.au www.ntmhc.org.au

ABN: 85 394 277 399

Lachlan Rowe MICDA

1/18 Bauhinia Street - Nightcliff Community Centre

PO Box 157 Nightcliff, NT 0814

1/06/2026

Submission:

Community Affairs Legislation Committee

(Securing the NDIS for Future Generations) Bill 2026

The Northern Territory Mental Health Coalition (The Coalition) is the peak body for community managed mental health services across the Northern Territory. We work in collaboration with a wide network of community mental health organisations, people with lived experience, their families and supporters. We advocate at the local and national level with a vision to give all Territorians an opportunity to have the best possible mental health. As a peak body, the Coalition ensures a strong voice for member organisations and a reference point for governments providing advice on all issues relating to the provision of mental health services in the Northern Territory.

Submission 2746

Executive Summary

This submission supports the need for a sustainable, safe and accountable NDIS, but raises serious concerns about the proposed sequencing and impact of the reforms in the Northern Territory. In the NT, these changes risk shifting people from individualised NDIS supports into health, mental health, education, justice, employment and community-service systems that are not yet funded or equipped to receive them. The greatest risk is not reform itself, but reform implemented before equivalent, culturally safe, regionally available and accountable supports exist.

Key Recommendations

  1. Ensure service availability before any participant loses access or material support.

  2. Ensure functional-capacity assessment recognises psychosocial, cultural and remote disability impacts.

  3. Protect people being excluded when treatment is unavailable, or only partially effective.

  4. Adequately fund dedicated NT psychosocial community support systems

  5. Ensure children are not redirected from the NDIS to Thriving Kids until NT early childhood, health and education supports are operational.

  6. Recommission missing community-service infrastructure through hybrid, place-based and Aboriginal community-controlled models.

  7. Apply reforms in ways that strengthen safety without collapsing thin NT markets.

  8. Strengthen safeguards before plan suspension, revocation or reassessment.

  9. Require NT-specific implementation modelling across disability, health, mental health, education, justice, employment and community services.

Position Statement

In the Northern Territory, reform cannot be assessed only through national budget settings or standardised administrative design. The NT has thin provider markets, high delivery costs, remote and very remote communities, limited mainstream alternatives, significant cultural and language diversity, and a community-service sector that has already been reshaped by the NDIS rollout. These conditions mean that national reforms can have disproportionate and unintended impacts if implemented without specific safeguards.

The central concern is unsafe sequencing. People should not be moved out of NDIS supports, or have material supports reduced, unless an alternative service is funded, available, culturally safe, geographically reachable and accountable for providing the relevant support. This is particularly important for people with psychosocial disability, children with developmental delay or autism, First Nations participants, people in remote communities, and people whose support needs intersect with health, education, justice, housing, AOD, family violence, employment and community-service systems. The NT needs clear transition conditions, remote-market safeguards and funded replacement infrastructure before people are moved from individualised NDIS support into systems that are not yet able to receive them.

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Submission 2746

Recommendations

  1. Require a service-availability transition test before any participant loses access or material support.

The Bill proposes major changes to access, reassessment, support categories and plan management, but the NT does not currently have equivalent mainstream or foundational supports available across regions. If people lose NDIS access or material support before replacement services exist, unmet need will shift to hospitals, emergency departments, schools, police, courts, corrections, homelessness services, families and overstretched community organisations. This would not reduce need; it would move costs and risk into less suitable systems. The legislation and implementation rules should require a service-availability test before access is revoked or supports are materially reduced. That test should confirm that the alternative support is funded, available, culturally safe, geographically reachable and accountable.

  1. Ensure functional-capacity assessment recognises episodic, fluctuating, psychosocial, cultural and remote-context disability impacts.

The current NDIS Act already requires permanent impairment and substantially reduced functional capacity; the proposed reforms would change how functional capacity is assessed and applied. A standardised assessment that does not account for episodic impairment, fluctuating conditions, trauma, communication barriers, cultural context, informal support availability and remote service gaps may underestimate real support need. This is particularly risky for psychosocial disability, cognitive disability, neurodevelopmental disability and people whose functioning changes depending on environment and support. Functional-capacity assessment should be designed to assess function over time and across settings, not only at a single point in time. Assessment rules should require consideration of culture, language, remoteness, informal support, housing stability, service availability and the impact of withdrawal of support.

  1. Protect people with psychosocial disability from being excluded because treatment is unavailable, incomplete or only partially effective.

The Bill’s permanence and treatment requirements may create specific risks for people with psychosocial disability. Treatment can improve symptoms without removing long-term functional impairment, and in the NT many people cannot access timely, specialist, continuous or culturally appropriate treatment. If lack of treatment access is interpreted as evidence that a person has not exhausted appropriate treatment, people may be excluded because services were unavailable rather than because their disability support needs are not real. The legislation should make clear that inability to access treatment, specialist assessment or therapy cannot be used against an applicant or participant. Psychosocial disability should be recognised as often fluctuating but still enduring, with NDIS access preserved for people with severe and long-term functional impairment.

  1. Establish a dedicated NT psychosocial community support system outside, but connected to, the NDIS.

The NT does not have a comprehensive, specialist, community-based psychosocial support system capable of absorbing people who may lose or experience reductions in NDIS-funded psychosocial supports. Without such a system, people will present later, sicker and in crisis, increasing pressure on emergency departments, acute mental health services, AOD services, homelessness services, police, corrections and families. Clinical mental health services cannot substitute for practical daily-living support, recovery-oriented community support, peer work,

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Submission 2746

housing coordination, social connection and supported participation. The Commonwealth and NT Government should jointly fund a dedicated psychosocial community support system for people who need support but do not meet, or no longer meet, NDIS access. This system should include assertive outreach, peer-led supports, culturally safe social and emotional wellbeing models, housing and AOD coordination, family support, and step-up/step down community options.

  1. Ensure children are not redirected from the NDIS to Thriving Kids until NT early childhood, health and education supports are operational.

The proposed changes for children aged 8 and under with developmental delay and/or autism depend on the existence of Thriving Kids and stronger mainstream supports. In the NT, early childhood, allied health, paediatric, school inclusion and family support services are already limited, especially outside major centres. If children are redirected before replacement supports are operational, their needs may be reframed as behaviour, attendance, parenting or school-management problems rather than developmental and disability support needs. Thriving Kids should be operating in the NT before any child is redirected from NDIS access. It must be funded to provide actual support, not only referral, and must be integrated with schools, early childhood services, Aboriginal community controlled services, allied health and family support.

  1. Recommission missing community-service infrastructure through hybrid, place-based and Aboriginal community-controlled models.

The NDIS rollout shifted many flexible, relationship-based and community-level support functions into individualised funding arrangements, and some community services either became NDIS providers, narrowed their work or ceased providing broader supports. If NDIS supports are reduced without recommissioning these functions, people will be referred into services that no longer exist, are not funded for this role, or are unavailable outside major centres. This is a service-function problem, not a provider-preservation problem. The NT requires hybrid commissioning: individualised NDIS funding where markets work, block-funded foundational supports where markets cannot work, and place-based commissioning in remote and thin-market areas. Aboriginal community-controlled organisations should be resourced to design and deliver culturally governed supports where community trust, language, kinship, Country and cultural authority are central to effective support.

  1. Apply provider registration and commissioning reforms in ways that strengthen safety without collapsing thin NT markets.

The NT has real problems with provider quality, exploitation, overservicing and plan exhaustion, and stronger safeguards are needed. However, registration, panel arrangements and commissioned provider models can also reduce choice and local supply if compliance costs force smaller, regional, specialist or community-controlled providers out of the market. In thin markets, fewer providers does not automatically mean safer providers; it can mean no provider at all. Registration and commissioning reforms should be risk-proportionate, staged and supported by transition funding. Small providers, Aboriginal community-controlled organisations and regional organisations should receive practical compliance support so safety improves without reducing local availability.

  1. Strengthen safeguards before plan suspension, revocation or reassessment, especially for people who are hard to contact.

The Bill includes stronger plan administration, reassessment and contact-failure mechanisms. In the NT, people may be difficult to contact because of unstable housing, phone disconnection, hospitalisation, incarceration, remote travel, cultural obligations, family violence, language barriers, cognitive impairment, psychosocial disability or

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Submission 2746

distrust of government systems. A failure of contact should not become an exit pathway from disability support. Before suspension or revocation, the NDIA should be required to use multiple contact methods, check relevant nominee, guardian, hospital, correctional and service-system information where lawful, and offer independent advocacy. Reinstatement should be simple where contact failure was caused by vulnerability, remoteness or service-system failure.

  1. Require NT-specific implementation modelling across disability, health, mental health, education, justice, employment and community services.

The likely impact of the Bill in the NT cannot be understood only through national participant numbers or national expenditure modelling. The NT needs specific modelling of how access changes, support-category reductions, child pathway changes, psychosocial reforms, provider registration and commissioning will affect local service systems. Without this modelling, reform risks creating hidden cost-shifting into health, education, justice, employment, housing, AOD, family support and community services. The Commonwealth and NT Government should publish NT-specific implementation modelling before major access or support reductions commence. This modelling should include participant cohorts, regional impacts, workforce capacity, service availability, market viability, expected demand transfer and funding required to prevent service gaps.

Final Statement

This submission supports a sustainable and accountable NDIS, but sustainability cannot be achieved by moving people from one system into another system that is not ready to support them. In the Northern Territory, the proposed reforms interact with thin markets, remote delivery costs, limited mainstream alternatives, an underdeveloped psychosocial support system, pressure on schools and health services, and a community-service sector already reshaped by the NDIS rollout. If reform proceeds without enforceable transition safeguards, the result will not be genuine savings or better targeting; it will be unmet need, crisis demand, cost-shifting and greater pressure on families, communities and frontline services.

The Commonwealth should not proceed with access restrictions, material support reductions or redirection into foundational or mainstream supports in the NT unless those supports are funded, operating, culturally safe, regionally available and accountable. The NT does not need an exemption from reform. It needs a reform pathway that recognises local conditions and prevents people with disability from being left between systems. The call to action is clear: secure the future of the NDIS by strengthening integrity and sustainability, but do not do so by creating new service gaps for Territorians with disability, psychosocial disability, developmental needs and complex support needs.

Kind Regards,

Lachlan Rowe MICDA

Peer Advocate

NT Mental Health Coalition

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Reference list Australian Government Department of Health, Disability and Ageing. (2026). NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 – Fact sheet. Canberra: Australian Government. Australian Government Department of Health, Disability and Ageing. (2026). NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026: About the changes to the NDIS. Canberra: Australian Government. Australian Government Department of Health, Disability and Ageing. (2026). Securing the NDIS for future generations. Canberra: Australian Government. Australian Parliament. (2026). National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill

  1. Parliament of Australia. Australian Parliament. (2026). Explanatory Memorandum: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. Parliament of Australia. Australian Parliament, Senate Community Affairs Legislation Committee. (2026). Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. Parliament of Australia. Parliamentary Library. (2026). Bills Digest: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. Parliament of Australia. National Disability Insurance Agency. (2026). Northern Territory statistics as at 31 March 2026. Canberra: NDIA. National Disability Insurance Agency. (2026). Quarterly Report to Disability Ministers: Q3 2025–26 appendices. Canberra: NDIA. National Disability Insurance Agency. (2026). Federal Budget and NDIS laws update. Canberra: NDIA.

Recommendation 1 Require a service-availability transition test before any participant loses access or material support. Australian Government Department of Health, Disability and Ageing. (2026). NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 – Fact sheet. Canberra: Australian Government. Australian Government Department of Health, Disability and Ageing. (2026). NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026: About the changes to the NDIS. Canberra: Australian Government. Parliamentary Library. (2026). Bills Digest: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. Parliament of Australia. People with Disability Australia. (2026). PWDA submission to the Inquiry into the NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026. PWDA. Disability Advocacy Network Australia, Children and Young People with Disability Australia, Community Mental Health Australia, People with Disability Australia and other disability representative organisations. (2026). Joint disability representative organisation statements and advocacy on foundational supports and NDIS reform sequencing. Down Syndrome Australia. (2026). Joint Statement: Concerns Over Rushed NDIS Reforms. Down Syndrome Australia.

Recommendation 2 Ensure functional-capacity assessment recognises episodic, fluctuating, psychosocial, cultural and remote-context disability impacts. Australian Government Department of Health, Disability and Ageing. (2026). NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 – Fact sheet. Canberra: Australian Government. Australian Parliament. (2026). Explanatory Memorandum: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. Parliament of Australia. Parliamentary Library. (2026). Bills Digest: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. Parliament of Australia. People with Disability Australia. (2026). PWDA submission to the Inquiry into the NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026. PWDA. Women With Disabilities Australia. (2026). Submission: Gendered Risks of the NDIS Amendment Bill 2026. WWDA. Down Syndrome Australia. (2026). DSA Consortium Response to “Securing the NDIS”. Down Syndrome Australia.

Recommendation 3 Protect people with psychosocial disability from being excluded because treatment is unavailable, incomplete or only partially effective. Community Mental Health Australia. (2026). Concerning NDIS Senate inquiry pace. CMHA.

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Mental Health Coordinating Council. (2026). NDIS reforms raise key implications for psychosocial supports. MHCC. People with Disability Australia. (2026). PWDA submission to the Inquiry into the NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026. PWDA. Women With Disabilities Australia. (2026). Submission: Gendered Risks of the NDIS Amendment Bill 2026. WWDA. Parliamentary Library. (2026). Bills Digest: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. Parliament of Australia. Australian Government Department of Health, Disability and Ageing. (2026). NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 – Fact sheet. Canberra: Australian Government.

Recommendation 4 Establish a dedicated NT psychosocial community support system outside, but connected to, the NDIS. Community Mental Health Australia. (2026). Concerning NDIS Senate inquiry pace. CMHA. Mental Health Coordinating Council. (2026). NDIS reforms raise key implications for psychosocial supports. MHCC. National Disability Insurance Agency. (2026). Northern Territory statistics as at 31 March 2026. Canberra: NDIA. National Disability Insurance Agency. (2026). Quarterly Report to Disability Ministers: Q3 2025–26 appendices. Canberra: NDIA. Disability Advocacy Network Australia, Children and Young People with Disability Australia, Community Mental Health Australia, People with Disability Australia and other disability representative organisations. (2026). Joint disability representative organisation statements and advocacy on foundational supports and NDIS reform sequencing. NT Disability Advocacy Consortium. (2026). NT Disability Advocacy Consortium warns Federal Budget NDIS changes could leave Territorians behind. Darwin Community Legal Service.

Recommendation 5 Ensure children are not redirected from the NDIS to Thriving Kids until NT early childhood, health and education supports are operational. Children and Young People with Disability Australia. (2026). Explainer: Federal Budget 2026–27. CYDA. Children and Young People with Disability Australia. (2026). A “fair crack” shouldn’t exclude disabled young Australians. CYDA. Children and Young People with Disability Australia. (2026). Thriving Kids. CYDA. Down Syndrome Australia. (2026). DSA Consortium Response to “Securing the NDIS”. Down Syndrome Australia. Down Syndrome Australia. (2026). Update on proposed NDIS changes. Down Syndrome Australia. National Disability Insurance Agency. (2026). Northern Territory statistics as at 31 March 2026. Canberra: NDIA. National Disability Insurance Agency. (2026). Quarterly Report to Disability Ministers: Q3 2025–26 appendices. Canberra: NDIA.

Recommendation 6 Recommission missing community-service infrastructure through hybrid, place-based and Aboriginal community controlled models. Australian Government Department of Health, Disability and Ageing. (2026). NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026: About the changes to the NDIS. Canberra: Australian Government. Children and Young People with Disability Australia. (2026). Explainer: Federal Budget 2026–27. CYDA. People with Disability Australia. (2026). PWDA submission to the Inquiry into the NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026. PWDA. Disability Advocacy Network Australia, Children and Young People with Disability Australia, Community Mental Health Australia, People with Disability Australia and other disability representative organisations. (2026). Joint disability representative organisation statements and advocacy on foundational supports and NDIS reform sequencing. NT Disability Advocacy Consortium. (2026). NT Disability Advocacy Consortium warns Federal Budget NDIS changes could leave Territorians behind. Darwin Community Legal Service. Down Syndrome Australia. (2026). DSA Consortium Response to “Securing the NDIS”. Down Syndrome Australia.

Recommendation 7 Apply provider registration and commissioning reforms in ways that strengthen safety without collapsing thin NT markets. Australian Government Department of Health, Disability and Ageing. (2026). NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 – Fact sheet. Canberra: Australian Government.

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Submission 2746

Australian Government Department of Health, Disability and Ageing. (2026). NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026: About the changes to the NDIS. Canberra: Australian Government. National Disability Insurance Agency. (2026). Federal Budget and NDIS laws update. Canberra: NDIA. NDIS Quality and Safeguards Commission. (2026). Crackdown on NDIS fraud and exploitation in Northern Territory. Canberra: NDIS Quality and Safeguards Commission. NT Disability Advocacy Consortium. (2026). NT Disability Advocacy Consortium warns Federal Budget NDIS changes could leave Territorians behind. Darwin Community Legal Service. Down Syndrome Australia. (2026). DSA Consortium Response to “Securing the NDIS”. Down Syndrome Australia. People with Disability Australia. (2026). PWDA submission to the Inquiry into the NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026. PWDA.

Recommendation 8 Strengthen safeguards before plan suspension, revocation or reassessment, especially for people who are hard to contact. Australian Government Department of Health, Disability and Ageing. (2026). NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 – Fact sheet. Canberra: Australian Government. Australian Parliament. (2026). Explanatory Memorandum: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. Parliament of Australia. Parliamentary Library. (2026). Bills Digest: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. Parliament of Australia. People with Disability Australia. (2026). PWDA submission to the Inquiry into the NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026. PWDA. Women With Disabilities Australia. (2026). Submission: Gendered Risks of the NDIS Amendment Bill 2026. WWDA. Justice and Equity Centre. (2026). Explainer: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. Justice and Equity Centre.

Recommendation 9 Require NT-specific implementation modelling across disability, health, mental health, education, justice, employment and community services. National Disability Insurance Agency. (2026). Northern Territory statistics as at 31 March 2026. Canberra: NDIA. National Disability Insurance Agency. (2026). Quarterly Report to Disability Ministers: Q3 2025–26 appendices. Canberra: NDIA. NT Disability Advocacy Consortium. (2026). NT Disability Advocacy Consortium warns Federal Budget NDIS changes could leave Territorians behind. Darwin Community Legal Service. Community Mental Health Australia. (2026). Concerning NDIS Senate inquiry pace. CMHA. Children and Young People with Disability Australia. (2026). Explainer: Federal Budget 2026–27. CYDA. People with Disability Australia. (2026). PWDA submission to the Inquiry into the NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026. PWDA. Disability Advocacy Network Australia, Children and Young People with Disability Australia, Community Mental Health Australia, People with Disability Australia and other disability representative organisations. (2026). Joint disability representative organisation statements and advocacy on foundational supports and NDIS reform sequencing. Australian Government Department of Health, Disability and Ageing. (2026). NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026: About the changes to the NDIS. Canberra: Australian Government.

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