NationalNationalDisabilityDisabilityInsuranceInsuranceSchemeSchemeAmendmentAmendment (Securing(Securing thetheNDISNDISforforFutureFutureGenerations)Generations)Bill Bill20262026 Submission 2850
Plan Sidekick submission
Samantha (Sami) Gale
Plan Sidekick Founder,PublicPlansubmissionSidekick
The person behind the paperwork. June 2026
Introduction
I, Samantha (Sami) Gale, welcome the opportunity to provide a submission in response to the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 (referred to in this submission as “the Bill”).
I am the founder of Plan Sidekick, a participant-side app in development for those with a disability including NDIS participants and their carers. This submission speaks only from the builder side: what the Bill looks like to someone trying to build a small, participant-facing tool that closes a gap the Scheme has not yet closed itself which must remain viable in order to reduce the strain on carers, participants, their providers, the NDIS, and the community as a whole.
Put simply, Plan Sidekick keeps a participant’s plan, the supports they are using, and the evidence and receipts that back those supports in one place that is editable and shareable with the people they trust. The tool does not deliver clinical supports. It helps participants manage the administrative side of receiving them.
I support reform of the NDIS in principle, and I support most of the Bill’s anti-fraud intent. Schedule 2 reaches for real problems, and the Scheme will be healthier when wrongdoing on the provider side is dealt with proportionately. I do not support the Bill in its current form, because as drafted it will obstruct the small, participant-side innovation pipeline the Scheme needs.
My submission focuses on the implications of the proposed amendments for participant-side tool builders, the families building from inside affected households, and the administrative load the Bill places on participants and their unpaid carers.
Overview of key concerns
I acknowledge the Government’s objective to ensure the long-term sustainability of the NDIS. I also raise that several proposed measures risk unintended consequences for the small, participant-side innovation pipeline that helps the Scheme function day to day. Restricting that pipeline while widening the administrative load it carries works against the Bill’s own sustainability goal.
Key areas of concern include:
1 Section 10C registration scope is ambiguous for admin-tool builders
2 Mandatory registration is calibrated for established providers, not new entrants
NationalNationalDisabilityDisabilityInsuranceInsuranceSchemeSchemeAmendmentAmendment (Securing(Securing thetheNDISNDISforforFutureFutureGenerations)Generations)Bill Bill20262026 Submission 2850
Plan Sidekick submission
3 The Bill widens admin load on families and narrows the supply of tools that close it
4 Automation provisions in sections 59B and 59E need participant-side data access
5 Record-keeping, claim timing, plan renewal, and digital-payment changes create direct app requirements
NationalNationalDisabilityDisabilityInsuranceInsuranceSchemeSchemeAmendmentAmendment (Securing(Securing thetheNDISNDISforforFutureFutureGenerations)Generations)Bill Bill20262026 Submission 2850
Plan Sidekick submission
- Section 10C registration scope is ambiguous for admin-tool builders Relates to: s 10C(1)(b).
Proposed s 10C(1)(b) extends the definition of “NDIS provider” to a person who provides supports or services to people with disability “prescribed by the rules.” It is not clear, on the face of the Bill, whether software that helps a participant manage their plan, prepare for renewals, or track evidence falls within “supports or services.”
If the rules treat pure participant-side admin software as a prescribed support or service, a small builder may be pulled into provider obligations, registration, or enrolment settings before they can safely launch. If the rules do not intend that result, the Bill or the rules should say so explicitly. Without that clarification, a small builder faces a chilling choice: either design as if the full provider-compliance pathway applies, which most independent builders cannot absorb at pilot stage, or assume the tool is outside scope and risk regulatory action later.
The Explanatory Memorandum confirms the scope is intended to be set by delegated rules. Without a statutory carve-out, or an explicit head-of-power for the rules to exclude software that does not deliver clinical supports, the rules can be drawn to include software, exclude software, or be silent. Each of those outcomes carries operational risk the Bill itself does not resolve.
Recommendations
Clarify section 10C(1)(b) so that pure admin and tools-only builders, software that does not deliver clinical supports and that is purchased by the participant rather than billed against a plan, are not swept into provider registration. A short subsection in the Act, of the kind drafted at clause level for similar carve-outs elsewhere in the NDIS Act, would resolve this without weakening the registration regime where it matters.
NationalNationalDisabilityDisabilityInsuranceInsuranceSchemeSchemeAmendmentAmendment (Securing(Securing thetheNDISNDISforforFutureFutureGenerations)Generations)Bill Bill20262026 Submission 2850
Plan Sidekick submission
- Mandatory registration is calibrated for established providers, not for new entrants
Relates to: s 10C, Schedule 2 Parts 5 and 6.
The administrative requirements that come with the Bill’s provider-visibility package, including registration for higher-risk supports, provider enrolment, payment controls, record-keeping, and the future plan-management panel, assume an operating provider with revenue, compliance staff, and the ability to absorb fixed costs across many participants. The Bill as drafted does not provide enough proportionate treatment for small businesses, sole traders, startups, or tools-only entrants at the design or pilot stage. That includes my own startup, and the broader small-provider end of the disability sector that participants rely on for choice, capacity, and innovation.
A registration regime that does not distinguish a national provider from a single-person team building a participant-side app will, in practice, function as a barrier to entry across the entire small-provider end of the market. Submissions from the broader self-managed and small-provider community make the same case from different angles, including Self Manager Hub.
Recommendations
Phase in registration for small and new entrants under a proportionate compliance regime, set in the Act. A clear small-business and sole-trader threshold, sized to the practical reality of the disability sector’s small-provider end, would preserve the integrity intent of Schedule 2 without closing off the supply of new providers and new tools at the start of their life.
NationalNationalDisabilityDisabilityInsuranceInsuranceSchemeSchemeAmendmentAmendment (Securing(Securing thetheNDISNDISforforFutureFutureGenerations)Generations)Bill Bill20262026 Submission 2850
Plan Sidekick submission
- The Bill widens admin load on families and narrows the supply of tools that close it
Relates to: s 34A, s 48A, Schedule 2 Part 5 (90-day claim window).
The Bill shifts administrative load onto participants in two directions at once. It adds new processes at the access and assessment end, including functional-capacity changes, support-needs assessment settings, the permanence test under s 25A, the suspension grounds under s 40A, and automated administrative action under s 59B and related provisions. And it narrows the pathways participants have to push back, including a tighter test for participant-initiated reassessment under s 48A, an Agency decision window extended from 21 to 90 days under s 48(3), and a validation provision for computer-assisted decisions under s 59E(3) that may make automated decisions harder for participants to inspect or challenge. That load does not fall on the Agency. It falls on participants and their unpaid carers, who are already operating at capacity, often without any formal administrative training, frequently while managing their own disability or their child’s.
Each individual measure may be framed as an integrity, planning, or sustainability measure. The cumulative effect, however, is that participants and carers must track more deadlines, more evidence, more eligibility links, more claim windows, and more decision points.
Tools that close that load are part of how the Scheme stays sustainable, because they free human time that would otherwise be spent on paperwork to be spent on supports, on work, or on rest. The provisions that restrict tool supply, including the 90-day claim window in Schedule 2 Part 5, the reassessment restrictions in s 48A, and the support-reduction determinations in s 34A, do not appear to have been weighed against the administrative load they leave behind on the participant side.
The Department’s own public material says social, civic and community participation supports and capacity-building daily-activity supports will be reset when a plan comes up for renewal or reassessment. Whatever label is used, reductions or tighter resets in those areas will fall hardest on participants who currently rely on them most. Those are also the participants for whom the administrative load of managing a plan is heaviest, and for whom tools that close that load matter most. Restricting the supply of those tools at the same time as deepening the load they would otherwise carry compounds the impact at exactly the wrong end of the participant distribution.
Recommendations
Recognise in the Act that participant-side innovation is part of long-term Scheme sustainability, and treat barriers to it accordingly when assessing the proportionality of integrity measures. Where a provision shifts load onto participants and their carers, the impact assessment should weigh that load against the integrity benefit, not treat the participant side as a free resource.
NationalNationalDisabilityDisabilityInsuranceInsuranceSchemeSchemeAmendmentAmendment (Securing(Securing thetheNDISNDISforforFutureFutureGenerations)Generations)Bill Bill20262026 Submission 2850
Plan Sidekick submission
- Automation provisions in sections 59B and 59E need participant-side data access
Relates to: s 59B and s 59E.
I am not opposed to automated tools being used in the NDIS. Used carefully, automation can speed up administrative work, reduce inconsistency, and free human time for the decisions that genuinely need judgement. Two conditions must apply, however. A human must remain in the loop with final approval and review for any automated decision that affects a participant’s access, eligibility, or funding. And any decision, whether produced by software or by a person, must be open to contest. Both computers and people make mistakes, and the people affected need a workable path to challenge a decision.
If the Agency is going to rely on automated administrative action under proposed s 59B and related provisions, especially where the outcome affects access, funding, payments, or a participant’s ability to contest a decision, participants and the tools they use need access to the decision data and reasoning.
Without that access, an automated decision is opaque to the participant and to any tool trying to help them respond. Robodebt is a sufficient case study for what happens when automated decisions about vulnerable people cannot be inspected by the people they affect.
Recommendations
Require that a human remains in the loop, with final approval and review, for any automated determination under sections 59B or 59E that affects a participant’s access, eligibility, or funding. Mandate that every such decision, whether automated or made by a person, is open to a workable contest path: clear, accessible, and timely. And mandate participant-side API access to decision data and reasoning for any automated determinations made under proposed sections 59B and 59E, so participants and the tools they use can verify, understand and respond. This does not weaken the Agency’s ability to use automation where appropriate. It ensures the people the automation acts on, and the tools that help them, can see what it is doing.
- Additional provisions that directly affect participant-side tools Relates to: record-keeping and claim timing provisions, plan renewal, plan management commissioning, provider enrolment, Schedule 3 pricing and automation, and Schedule 4 new framework planning.
There are several additional practical impacts for participant-side tools like Plan Sidekick that should be considered expressly.
First, the proposed records and claims changes turn evidence management into a core participant burden. If participants or plan managers must keep payment records for three years and claims must be made within 90 days of service delivery, a participant-side app becomes part of the reliability infrastructure for lawful claiming: reminders, receipt capture, evidence storage, export, and audit trails are not optional convenience features. The Bill should recognise these tools as participant safeguards, not as suspect provider activity by default.
NationalNationalDisabilityDisabilityInsuranceInsuranceSchemeSchemeAmendmentAmendment (Securing(Securing thetheNDISNDISforforFutureFutureGenerations)Generations)Bill Bill20262026 Submission 2850
Plan Sidekick submission
Second, plan renewal and the end of plan rollovers change how budget tools must work. If unspent funds do not carry into the renewed plan, the app must help participants understand plan end dates, renewal timing, committed spend, and evidence needs well before a deadline. This is not just financial bookkeeping. It affects continuity of support and the ability to avoid avoidable underspend caused by administrative overload.
Third, the proposed plan-management panel and provider enrolment model affect integration pathways. A participant-side tool may currently plan a staged path from manual record-keeping to CSV exports, plan-manager partnerships, and later API or payment integration. If plan management becomes limited to a commissioned panel, and providers must enrol with validated payment details, those pathways depend on whether small software builders can interoperate with the new payment ecosystem on fair terms.
Fourth, the Government’s own NDIS App roadmap, including tap-and-go claiming and documentation thresholds, should not become the only digital participant pathway. A government app can make claiming easier, but it is unlikely to replace the broader organisational work families do around plans, providers, evidence, notes, tracking, reports, and trusted sharing. The Bill should support data portability so participants can use tools that fit their household.
Finally, new framework planning and support needs assessments make participant-side evidence more important, not less. If future budgets are shaped by functional capacity, life stage, environmental factors, and eligible-impairment links, participants need practical tools to assemble accurate evidence without turning daily life into a compliance file. The Bill should not make that task harder by leaving participant-side software in regulatory uncertainty.
NationalNationalDisabilityDisabilityInsuranceInsuranceSchemeSchemeAmendmentAmendment (Securing(Securing thetheNDISNDISforforFutureFutureGenerations)Generations)Bill Bill20262026 Submission 2850
Plan Sidekick submission
Closing
Sustainability comes from systems that work better for the people inside them. It does not come from cuts to support, or from barriers to the people building solutions. I ask the Committee to recommend the amendments above so the Bill’s integrity intent is preserved without closing off the participant-side tools the Scheme needs.