Submission 2861 — Name Withheld — NDIS Future Generations Bill | External submission

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 2861

1st June, 2026

Committee Secretariat

Inquiry: The National Disability Insurance Scheme Amendment (Securing the NDIS for

Future Generations) Bill 2026

Dear Committee Secretariat,

I am writing in my capacity as a Senior Clinical Neuropsychologist working across both public mental health services and private practice in Victoria. I provide assessment and ongoing intervention for individuals with complex neurodevelopmental, cognitive and psychiatric presentations many of whom rely heavily on supports funded through the

NDIS.  In my  clinical  work, my consumers  present  with  intersecting  cognitive

impairments, severe mental illness, behavioral dysregulation and high psychosocial risk. For these individuals, NDIS-funded supports are not supplementary, they are essential to maintaining safety, stability and community functioning. These supports often include

behavioral  support  implementation  which  ensures  stable  housing,  reduced

presentations to emergency services, reduced crisis presentation and enhanced daily functioning. As well as behavioural support, the consumers I support also require therapeutic input, structured daily living assistance and supervision to mitigate risks associated with mental state deteriorations, cognitive impairment and functional deterioration. For my consumers, the changes in funding which have already occurred have resulted in crisis presentations, hospitalisations, reductions in functional capacity and stress on family systems.

The proposed changes in this bill are causing further harm and distress to vulnerable participants. As a clinician, I wish to express significant concern regarding the proposed changes to the NDIS

Of particular concern is the proposed use of the ICAN tool to inform funding decisions. Whilst structured assessment approaches can support consistency across services, there are significant limitations that must be carefully considered, such as:

The ICAN tool does not appear to have sufficient independent validation across diverse clinical populations, particularly for individuals with autism, complex trauma and co-occurring psychiatric conditions. These concerns have been raised by Autism advocacy groups as well as the Australian Psychological Society.

• It risks oversimplifying functional capacity by reducing complex, context

dependent presentations into static scores

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 2861

It may not adequately capture the interaction between cognitive impairment, emotional regulation difficulties, sensory sensitivities and environmental

demands

It is unlikely to reflect fluctuations in functioning which are a defining feature of many neuropsychiatric and neurodevelopmental conditions
It does not incorporate the depth of clinical formulation typically required to understand risk, behavioural drivers, and support needs

In practice, individuals with intersecting disabilities often function very differently depending on the quality, consistency and skill level of supports provided. A tool which does not account for these dynamic and relational factors risks underestimating need and leading to inappropriate funding decisions.

From both a  clinical and systems  perspective, such changes are  likely  to be

counterproductive. Whilst intended to improve consistency and manage scheme costs, the downstream effects are likely to include significantly higher expenditure within the acute health systems and crisis services. More importantly, they result in substantial human costs including loss of autonomy, dignity, safety and quality of life.

I strongly urge that any proposed reforms to the NDIS:

Be informed by frontline clinical evidence and consultation with experienced practitioners
Include consideration of the needs and wishes expressed by peak advocacy groups
Avoid over-reliance on tools that may not capture the complexity of support needs
Safeguard supports for individuals with high-risk and intersecting needs
Consider long-term system impacts including increased demands on public health care services
Ensure continuity, flexibility and responsiveness in participant plans
Consider the costs to the NDIS participants, including their autonomy, community and economic participation, and quality of life as a result of proposed cuts and changes

The NDIS has become a critical component of the broader health and disability system. It has allowed many people with disability to participate in the community and workforce in a way which was not previously possible for them under older models of care. Reforms to the NDIS which do not adequately address the realities of complex disability risk unintended and potentially harmful consequences for individuals, families and services.

Yours sincerely,