Submission 2916 — Name Withheld — NDIS Future Generations Bill

Submission to the Senate Community Affairs Legislation Committee

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future

Generations) Bill 2026

Submitted by: Registered NDIS Behaviour Support Practitioner and Provisional Psychologist. Director of an NDIS registered provider and a private psychology practice. Date: 1 June 2026

Declaration of interest I make this submission as a registered NDIS Behaviour Support Practitioner and Provisional Psychologist, and as a Director of an NDIS registered provider and a private psychology practice. I have a financial interest in the delivery of NDIS supports, and I declare it openly. I make no claim to be a disinterested party. I do note that the participants this submission concerns are people who would be removed from the Scheme, whom I would in most cases lose as clients, so on the specific question before the Committee my interest does not point toward the position I am taking. I am not asking the Committee to preserve funding for my services. My evidence goes to one thing within my direct professional knowledge: what happens to a particular kind of participant when they are removed and directed to mainstream services, and whether that destination exists for them.

Scope of this submission This submission addresses one issue. The Bill tightens eligibility on the premise that participants who no longer meet the threshold can be supported by mainstream and foundational services instead. For a substantial group of participants, I am not able to identify what that destination would be in practice, and I do not believe it presently exists in a usable form. My concern is that the Bill places the burden on the participant and their clinicians to find a mainstream pathway after access is removed, rather than on the Scheme to establish that an accessible pathway exists before it is removed. Where no such pathway exists, the change does not transition a person to different support. It removes their support, and the need does not disappear. It transfers to participants, families and acute services.

The premise the Bill depends on

The case for tightening  eligibility rests on the assumption that there  is a

mainstream system ready to receive people who are moved out of the Scheme, and that the foundational supports promised under the wider reforms will fill the space between the NDIS and the general service system. I am not in a position to give the Committee evidence about the national foundational support rollout, its funding or its timetable, and I do not. My point is narrower and, I would suggest, more pressing because of that uncertainty: as matters stand today I cannot identify the service I would refer a participant like the one described below to, and the foundational supports intended to be that service are not yet operating in

a form  I can refer  to. Parliament  is being asked to legislate the removal

mechanism ahead of the destination. The sequencing should be the other way around, and the Bill should not commence the tightening until the receiving supports are demonstrably available.

Where these participants actually land I will describe a participant as Participant A. This is a composite, used to avoid identifying a real and current participant, but the profile is one I hold direct professional responsibility for and is not hypothetical. I would be willing to provide a de-identified case to the Committee on notice. Participant A has a

psychosocial  disability  arising  from  schizophrenia,  together  with  a  mild

intellectual disability and other co-occurring health conditions. Participant A can live independently, but only with substantial ongoing support to maintain that independence: support to manage medication and appointments, to keep a tenancy, to handle money and daily routines, and to recognise and respond to early signs of relapse before they escalate.

That profile is the one I am most concerned a tightened functional capacity threshold will misjudge. On a settled day, Participant A presents as capable and independent. That capability is real, but it is produced and held in place by the support. An assessment conducted on such a day, which reads independence as evidence of lower need, risks concluding that the threshold is no longer met. The fragility beneath the stability, and how quickly it unravels when support is withdrawn, is what the support exists to manage and is not reliably visible in a point-in-time assessment.

If Participant A is removed from the Scheme, the mainstream destinations available are, in my experience, limited and ill-matched to this need. The first is Medicare-subsidised psychology through a Mental Health Treatment Plan, which provides a capped number of sessions a year, each carrying a gap fee, and is designed for episodic treatment rather than the coordinated, sustained, multi domain support that keeps a person with schizophrenia and an intellectual disability living independently. The gap fee also rations it by income. The second is the public mental health system through NSW Health. There are community programs within that system, and I do not suggest there is nothing there. My experience of referring participants with this profile is that ongoing, coordinated psychosocial support of the kind the NDIS funds is difficult to obtain, that the public system is necessarily weighted toward acute risk, and that a person who is stable precisely because their support is working can fall below the threshold for ongoing care and re-enter the system at the point of crisis. I put this to the Committee as what I have observed in practice, not as a complete account of every program’s eligibility criteria.

The assessment instrument and what it will miss My concern about eligibility is compounded by the instrument that will give it effect. The new support needs assessment will be built on the Instrument for the Classification and Assessment of Support Needs, version 6 (I-CAN v6), provided by the University of Melbourne and the Centre for Disability Studies and rolling out from mid-2026. It is a strengths-based instrument administered as a semi

structured interview by a trained, accredited assessor across twelve life domains. A confirmed feature of the new model is that participants will no longer be required to provide reports from treating doctors or allied health professionals to set their plan budgets. I want to be measured here: I-CAN v6 has a long evidence base, and a strengths-based, person-centred approach has real merit for much of the participant population. My concern is specific to the presentations I work with most.

Removing the allied health report as the primary evidence source removes the document in which nuanced, fluctuating and masked presentations are actually captured. A great many of the participants I work with are autistic, and autistic masking is the clearest example of the problem. A masked presentation is, by definition, one in which the person suppresses or conceals their difficulty and presents as coping. A strengths-based interview conducted by a non-clinical assessor, oriented to what a person can do, is structurally likely to record that masked presentation at face value and to understate the support need behind it. The same risk applies to demand-avoidant profiles, to predominantly negative symptom presentations, and to executive dysfunction, where the difficulty is not visible in a single structured conversation and requires clinical interpretation to read correctly.

I am aware the NDIA has indicated that targeted assessments, and in some cases health professional reports, will remain available for participants with more complex needs. That is the right instinct, but as drafted it cannot be relied upon as a safeguard, for two reasons. It is discretionary and undefined, expressed as something a participant may be asked for rather than an entitlement with criteria that can be scrutinised. And, most importantly, masking defeats the very trigger that is meant to route a person to the more thorough pathway. The participant whose need is concealed by a capable presentation is precisely the one who will not be flagged as complex, and so will not reach the assessment that could see them. The safeguard is least available to the people who most need it.

The cost does not disappear When a participant like this loses funded support, the need does not resolve. On the basis of what I see clinically, it tends to re-emerge elsewhere, often at greater cost and harm: in relapse and acute mental health admissions, in lost tenancies, in contact with police, in pressure on families who absorb what the formal systems no longer carry, and in people going without until a crisis forces a response. I do not offer the Committee a costing of these effects, and I am not equipped to. My point is that they are real, foreseeable, and fall outside the NDIS ledger, so a saving booked from removing a participant is not the whole picture. If the Scheme’s modelling does not net off the costs that transfer to health, housing, justice and families, it will overstate the saving and understate the harm. The honest test of sustainability is the net effect across systems, not the reduction in one line of one budget.

What I am not arguing

I am not arguing that no participant should ever become ineligible. Where a person’s underlying disability or support need genuinely changes, reassessment and exit are legitimate, and a sustainable scheme requires them. My objection is

specific and twofold.  First, capability that exists only because  it  is being

supported should not be read as reduced need; that mistakes the effect of the support for the absence of disability. Second, no participant should be removed on the strength of an assumed mainstream alternative that has not been shown to exist and be accessible for that person. Those two limits would leave the Scheme’s ability to manage genuine change intact, while preventing the foreseeable harm this submission describes.

The participants least able to absorb this are the ones most exposed The people most likely to be moved out under a capability-based threshold, and least able to navigate or fund a mainstream alternative, are those whose disability is intermittent, masked or easily misread on a good day: psychosocial disability, intellectual disability, and autistic presentations that look like coping until the support is removed. They are also among the least able to self-advocate, to challenge an adverse assessment, or to pay an out-of-pocket gap. The design of the Bill therefore concentrates its harm on the participants with the least capacity to withstand it.

Recommendations

1. Eligibility should not be tightened until the mainstream and foundational supports the reforms rely on are designed, funded and demonstrably operating at the scale required to receive the participants who would be moved out of the Scheme.

2. The functional capacity assessment should be required to account for the supports currently sustaining a participant’s independence, so that

capability produced by support is not misread as evidence that support is no longer needed.

3. Before a participant is found ineligible, there should be a documented, individualised check that a genuine and accessible mainstream pathway exists for that person, rather than a general assumption that one does.

4. The retention of allied health and treating practitioner evidence should be an entitlement with published criteria, not a discretionary request, and participants with psychosocial disability, intellectual disability or masked or fluctuating presentations should have a defined right to a clinician-informed assessment pathway. A standardised interview by a non-clinical assessor should not be the sole basis for an eligibility or budget decision for these participants.

5. The Bill’s financial modelling should be required to account for the costs that shift to the health, housing and justice systems, and to families, when participants are removed, so that any claimed saving is assessed net of the cost it transfers.

I would welcome the opportunity to give evidence to the Committee on these matters.