Submission 2905 — Name Withheld — NDIS Future Generations Bill

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Submission to the Senate Community Affairs Legislation Committee

Inquiry into the National Disability Insurance Scheme Amendment (Securing the

NDIS for Future Generations) Bill 2026

Author: Name Withheld

Date: 1 June 2026

Submission made in a personal capacity.

Contact details provided separately to the Committee.

Submission to the Senate Community Affairs Legislation Committee: Inquiry into the National

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

Opening Statement:

I make this submission as a person living with disability, as the primary carer of a child who has received NDIS supports and as a policy professional with experience advising government on complex social policy issues. This combination of lived experience and policy experience informs my concerns regarding the practical implementation, governance, and long-term consequences of the proposed reforms. The views expressed are my own and should not be taken as representing any organisation, council, employer, government agency, or advisory body with which I am associated.

Executive Summary

This submission supports the objectives of maintaining the long-term sustainability, integrity and effectiveness of the National Disability Insurance Scheme (NDIS).

However, it raises concerns that several measures within the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 may create unintended consequences that undermine broader disability policy objectives and shift costs and risks onto individuals, families, states and territories.

The principal concern is not any individual reform measure in isolation, but the cumulative interaction between:

  • increased reliance on automated and standardised decision-making;
  • functional capacity assessments;
  • reduced flexibility within participant plans;
  • reduced community participation supports;
  • funding constraints;
  • expanded administrative powers; and
  • reliance on foundational supports that are not yet fully established. The submission identifies seven key risks:
  1. Increased medicalisation of disability and reduced individual choice.
  2. Erosion of the whole-of-person approach underpinning the NDIS.
  3. Increased isolation and segregation contrary to lessons from the Disability Royal Commission.
  4. Cost shifting to families, carers, states and mainstream systems.
  5. Disproportionate impacts on women and unpaid carers.
  6. Increased disadvantage for communities already experiencing structural barriers.
  7. Insufficient transparency, governance safeguards and consultation. 2 of 9

The submission recommends stronger safeguards around automated decision-making, preservation of meaningful human discretion, greater transparency and accountability, disability-led oversight, comprehensive impact assessments, and implementation arrangements that ensure foundational supports are operational before corresponding reductions in NDIS supports occur.

Introduction

I support the objectives of ensuring the long-term sustainability, integrity and effectiveness of the National Disability Insurance Scheme (NDIS).

However, I am concerned that several measures contained within the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 may create unintended consequences that undermine broader disability policy objectives, increase long-term costs to government, and reduce participation, inclusion and autonomy for people with disability.

My concerns are not directed at any individual reform measure in isolation.

Rather, they relate to the cumulative effect of multiple reforms occurring simultaneously, including:

  • increased reliance on automated and standardised decision-making;
  • greater use of functional capacity assessments;
  • reduced flexibility within plans and support arrangements;
  • expanded executive powers;
  • reduced community participation funding;
  • tighter expenditure controls; and
  • the assumption that foundational and mainstream services will absorb unmet need. Taken together, these changes risk shifting the Scheme away from a person centred model based on individual circumstances and towards a more standardised administrative model focused primarily on expenditure management.

This submission primarily addresses matters relating to participant access and planning arrangements, automated administrative decision-making, governance and accountability mechanisms, funding and support arrangements, and the broader impacts of the Bill on people with disability, carers and the disability support ecosystem.

  1. Risk of increased medicalisation and reduced individual choice One of the strengths of the NDIS has been its gradual movement away from purely medical models of disability towards a more holistic understanding of how disability affects participation in everyday life.

Several aspects of the Bill appear to move in the opposite direction.

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The proposed reforms may make access decisions more invasive, more medicalised, and less respectful of individual choice by increasing reliance on standardised functional assessments and impairment linked decision-making.

This creates risks for people whose disability:

  • fluctuates over time;
  • is not easily measured through standardised assessment tools;
  • is affected by environmental barriers;
  • involves psychosocial disability;
  • involves trauma or cumulative disadvantage; or
  • presents differently across cultural or gender groups. There is also a risk that people who cannot access, afford or tolerate treatment may face additional barriers when attempting to demonstrate eligibility or support needs.

Disability support should not become contingent on a person’s ability to navigate complex health systems, pay for specialist reports, or undertake treatment pathways that may be inaccessible or inappropriate.

  1. Risk of weakening the whole-of-person approach The NDIS was established to support people as whole individuals rather than as collections of separate impairments.

A recurring concern throughout the reforms is the potential narrowing of support decisions to specific impairments rather than considering the broader interaction between disability, environment, community participation, health, family circumstances and social inclusion.

A more narrowly impairment-based approach risks overlooking the reality that disability outcomes are often shaped by multiple interacting factors.

The practical result may be that support becomes less responsive to real-world needs, particularly for people with complex, intersecting or less visible disabilities.

  1. Risk of increasing isolation and segregation The Disability Royal Commission identified segregation and social exclusion as key conditions associated with increased violence, abuse, neglect and exclusion experienced by people with disability.

This finding should remain central to any future reform agenda.

Community participation supports are not simply discretionary social activities.

For many participants they provide:

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  • protection against social isolation;
  • opportunities for skill development;
  • pathways into education and employment;
  • informal safeguarding networks;
  • connection to culture and community; and
  • improved mental health and wellbeing. Reducing these supports before replacement systems are fully operational risks increasing isolation and dependence.

This is particularly concerning because the Bill enables funding reductions without clearly identifying how safety impacts will be monitored, how outcomes will be evaluated, or who will be responsible for addressing emerging gaps.

The risk is not merely reduced funding.

The risk is the gradual re-creation of conditions that disability policy has spent decades attempting to address.

  1. Cost-shifting is not the same as reform The Bill assumes that many unmet needs will be addressed through foundational supports and mainstream services.

However, many of these systems are already experiencing workforce shortages, long waiting times and significant demand pressures.

If disability support is withdrawn without equivalent alternatives being fully established, the likely result is not reduced need.

Rather, costs may be transferred to:

  • families and unpaid carers;
  • emergency health services;
  • mental health systems;
  • homelessness services;
  • child protection systems; and
  • state and territory governments. The need remains. Only the location of the cost changes.

This creates a risk that short-term savings within one part of government may generate greater expenditure and poorer outcomes elsewhere.

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  1. Disproportionate impacts on women and carers Any reduction in formal support inevitably increases reliance on unpaid support.

In Australia, women continue to undertake the majority of unpaid caring responsibilities.

Where support becomes harder to access, more restrictive, or less flexible, the burden frequently falls on mothers, partners, daughters and female family members.

This creates foreseeable risks including:

  • reduced workforce participation;
  • lower lifetime earnings;
  • reduced retirement savings;
  • increased financial insecurity;
  • carer burnout; and
  • poorer physical and mental health outcomes. While the Bill is neutral in its wording, its practical impacts may not be neutral in their effect.

These consequences should be explicitly assessed before implementation.

  1. Intersectional impacts The reforms are likely to have greater impacts on communities already experiencing structural disadvantage.

This includes:

  • Aboriginal and Torres Strait Islander peoples;
  • culturally and linguistically diverse communities;
  • LGBTQIA+ people with disability;
  • rural and remote Australians;
  • veterans and veteran families;
  • women with disability; and
  • people experiencing poverty or housing insecurity. These communities often face additional barriers in obtaining assessments, accessing services, navigating review processes and exercising their rights.

As reforms become more complex and more standardised, there is a risk that existing inequities become amplified.

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  1. Governance, transparency and consultation The Bill introduces significant changes to the operation of the NDIS, yet many key implementation details remain unclear.

Particular concerns include:

  • automated decision-making safeguards;
  • transparency of assessment methodologies;
  • monitoring and evaluation arrangements;
  • oversight of funding reductions;
  • review mechanisms; and
  • accountability for unintended consequences. There is also concern that reforms of this scale have progressed without sufficient involvement of people with disability, representative organisations, carers, service providers, community stakeholders, and state and territory governments. Meaningful co-design is not simply a consultation process; it is an important safeguard against unintended consequences, implementation failure, and loss of public confidence.

The principle of ‘Nothing About Us Without Us’ should not be viewed as an aspirational slogan.

It is an important governance safeguard that helps identify risks before they become systemic failures.

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Recommendations

The Committee should consider:

  1. Strengthening safeguards around automated and semi-automated decision-making.
  2. Preserving meaningful human discretion in all significant decisions.
  3. Undertaking a comprehensive human rights and intersectional impact assessment.
  4. Publishing transparent monitoring and evaluation frameworks before implementation.
  5. Ensuring foundational supports are operational before corresponding NDIS reductions occur.
  6. Preserving flexibility within participant plans.
  7. Establishing stronger disability-led oversight and co-design mechanisms.
  8. Reviewing gendered impacts on unpaid carers.
  9. Conducting regular independent reviews of implementation outcomes.
  10. Requiring publication of implementation reviews within 12 and 24 months of commencement, including impacts on participant outcomes, carers, service availability, and community participation.

Conclusion

The central question before Parliament is not whether the NDIS should change.

It is whether the proposed reforms are sufficiently designed, sequenced and safeguarded to avoid creating new problems while attempting to solve existing ones.

The greatest risk is not any individual measure contained within the Bill.

It is the cumulative interaction between reduced flexibility, increased standardisation, automation supported administration, funding constraints and incomplete replacement systems.

Without stronger safeguards, there is a significant risk that reforms intended to improve sustainability may unintentionally increase exclusion, transfer costs to families and other service systems, weaken individualised support, and diminish progress towards Australia’s longstanding disability inclusion objectives.

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Key References:

Australian Bureau of Statistics (ABS) 2024. Disability, Ageing and Carers, Australia, ABS, Canberra. Available at: https://www.abs.gov.au/statistics/health/disability/disability-ageing-and-carers-australia-summary findings/latest-release

Australian Government 2026. National Disability Insurance Scheme Amendment (Securing the NDIS for Future

Generations) Bill 2026, Parliament of Australia, Canberra. Available at: https://www.aph.gov.au https://www.aph.gov.au/Parliamentary_Business/Bills_Legislation/Bills_Search_Results/Result?bId=r7487

Australian Government 2026. National Disability Insurance Scheme Amendment (Securing the NDIS for Future

Generations) Bill 2026: Explanatory Memorandum, Parliament of Australia, Canberra. Available at: https://www.aph.gov.au

Australian Parliamentary Library 2026. Bills Digest No. 65, 2025-26: National Disability Insurance Scheme

Amendment (Securing the NDIS for Future Generations) Bill 2026, Department of Parliamentary Services, Canberra. Available at: https://www.aph.gov.au/Parliamentary_Business/Bills_Legislation/bd/bd2526/26bd065

Commonwealth of Australia 2021. Australia’s Disability Strategy 2021-2031, Department of Social Services,

Canberra. Available at: https://www.disabilitygateway.gov.au/ads

Independent Review into the National Disability Insurance Scheme 2023. Working Together to Deliver the NDIS, Commonwealth of Australia, Canberra. Available at: https://www.ndisreview.gov.au/resources/reports/working together-deliver-ndis

Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability 2023. Final Report,

Commonwealth of Australia, Canberra. Available at: https://disability.royalcommission.gov.au/publications/final report

Royal Commission into the Robodebt Scheme 2023. Report of the Royal Commission into the Robodebt Scheme, Commonwealth of Australia, Canberra. Available at: https://robodebt.royalcommission.gov.au/publications/report

United Nations 2006. Convention on the Rights of Persons with Disabilities, United Nations, New York. Available at: https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-disabilities.html

United Nations Committee on the Rights of Persons with Disabilities 2022. Concluding Observations on the Combined Second and Third Periodic Reports of Australia, United Nations, Geneva. Available at: https://tbinternet.ohchr.org

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