Submission 2979 — Bright Journey Disability Support Services — NDIS Future Generations Bill

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Submission to the Senate Community Affairs Legislation Committee

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

Generations) Bill 2026

Submitted by: Sean Rich - Bright Journey Disability Support Services

ABN: 69687931942

ACN: 687931942

NDIS Registration ID: 4-LQKTRD0

Contact: Sean Rich, Business Development and Intake Officer

Email:

Date: 3rd July 2026

Dear Committee Secretary,

Bright Journey Disability Support Services welcomes the opportunity to provide a short submission in relation to the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

Bright Journey supports the long-term sustainability, integrity and safety of the National Disability Insurance Scheme. We support appropriate action to reduce fraud, strengthen accountability, improve quality and ensure that the Scheme remains available for people with permanent and significant disability.

However, reform must not unintentionally reduce access to essential supports, increase risk for participants with complex needs, or place unrealistic administrative pressure on ethical providers already working within a complex and tightly regulated environment.

Our submission is made from the perspective of a Victorian disability support provider supporting people with complex support needs, psychosocial disability, intellectual disability, autism, emotional regulation challenges, supported independent living needs and community participation goals.

  1. Participant safety and continuity of support must be protected Any changes to eligibility, reassessments, plan structures, funding rules or definitions of NDIS supports must include strong protections to ensure participants are not left without essential support while decisions are being made.

For many participants, support is not optional. It is the difference between stability and crisis, medication compliance and health deterioration, safe housing and homelessness, community participation and isolation, or family sustainability and carer breakdown.

Bright Journey is concerned that if reforms are implemented without clear safeguards, participants with complex needs may experience abrupt funding reductions, delays, uncertainty or gaps in support. This is particularly risky where participants rely on daily support, supported independent

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living, behaviour support, high-intensity personal supports, or assistance to maintain housing and safety.

We recommend that the Bill include clear continuity-of-support protections so existing supports are not reduced, paused or removed until appropriate evidence has been reviewed, the participant has had a genuine opportunity to respond, and any alternative supports are confirmed, available and appropriate.

  1. The NDIS needs a clinically accepted joint protocol for complex cases Bright Journey recommends that the National Disability Insurance Scheme adopt a clinically accepted joint protocol for participants with complex support needs, similar to the coordinated practice frameworks used in the out-of-home care sector.

In out-of-home care, complex needs often require shared responsibility between child protection, health, mental health, education, carers, disability services and community supports. A similar model is urgently needed within the NDIS for participants whose needs intersect with health, mental health, housing, justice, family services, child protection, homelessness, drug and alcohol services, and mainstream community systems.

Too often, participants with complex disability-related needs are passed between systems, with each system arguing that another service is responsible. This creates risk, delays support, increases crisis presentations, and places pressure on families, carers and providers.

A clinically accepted joint protocol should set out:

Which system is responsible for which type of support.

How NDIS, health, mental health, housing, justice, child protection and mainstream services must communicate when a participant has complex needs.

How urgent risks are escalated where a participant’s safety, housing, medication compliance, behaviour support, family stability or community access is at risk.

How clinical evidence, provider evidence, functional observations and participant/family evidence should be considered together.

How disputes between systems are resolved without leaving the participant unsupported.

How continuity of support is maintained while funding, eligibility or responsibility questions are being resolved.

How providers, support coordinators, allied health professionals, clinicians, carers and government agencies can work from one shared support-risk framework.

This type of joint protocol would improve participant safety, reduce crisis-driven decision-making, reduce duplication, improve accountability and prevent participants from falling through gaps between the NDIS and mainstream services.

Bright Journey recommends that the Bill, or its implementation framework, require the development of a nationally consistent joint protocol for complex NDIS participants, developed with people with disability, clinicians, providers, families, carers, allied health professionals and relevant state and territory systems.

  1. Reforms must be co-designed with people with disability, families and frontline providers 2 of 5

Bright Journey supports reform that is practical, evidence-based and informed by the lived experience of participants and the operational experience of providers.

Providers see firsthand where the current system works, where it creates risk, and where administrative processes prevent participants from receiving timely support. Support workers, support coordinators, allied health professionals, families and providers often understand the daily functional impact of disability in ways that cannot be captured by short assessments or paperwork alone.

We recommend that any major reform to eligibility, planning, funding categories, reassessments, plan management, provider obligations or administrative decision-making be co-designed with people with disability, families, carers, providers and representative organisations before implementation.

  1. Clear and fair evidence requirements are essential Bright Journey supports appropriate evidence requirements, but these must be realistic, accessible and fair.

Participants often face barriers to obtaining reports from occupational therapists, psychologists, speech pathologists, neurologists, physiotherapists and other professionals. Report delays, cost, waitlists and limited access to specialists can significantly affect a participant’s ability to prove need, even where the functional impact is clear.

We recommend that the Bill and related rules ensure evidence requirements do not disadvantage participants who have limited access to specialists, communication barriers, psychosocial disability, cognitive disability, unstable housing, rural or regional access issues, or limited informal support.

The NDIA should be required to consider functional evidence from a broad range of sources, including support worker observations, provider reports, incident history, family/carer evidence, allied health reports, medical evidence, clinical opinion and participant statements.

  1. Fraud prevention should not punish legitimate participants or ethical providers Bright Journey strongly supports action against fraud, exploitation and unsafe practice. Fraud harms participants, damages public trust and undermines ethical providers.

However, fraud prevention must be targeted and proportionate. It should not create excessive red tape that delays legitimate supports, discourages quality providers, or places participants at risk because services cannot be delivered while administrative issues are resolved.

We recommend that the Committee distinguish clearly between fraudulent conduct, administrative error, honest provider confusion, plan interpretation issues and participant complexity. Compliance systems should protect participants while supporting providers to do the right thing through clear guidance, education, transparent rules and timely communication.

  1. Mainstream and foundational supports must be real before NDIS supports are reduced The success of NDIS reform depends on whether mainstream services and foundational supports are actually available, accessible and appropriate.

Bright Journey is concerned that participants may be redirected away from the NDIS before alternative systems are ready. In practice, many participants already face barriers accessing housing,

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mental health services, transport, health care, education, employment pathways, community programs and family support.

We recommend that no participant lose access to necessary NDIS support on the assumption that another system will assist them unless that support is confirmed, available, affordable, accessible and appropriate to their disability-related needs.

  1. Provider sustainability must be considered High-quality disability support requires a stable workforce, proper supervision, training, compliance systems, insurance, incident management, recruitment, onboarding and quality assurance. These costs are real.

Bright Journey recommends that reforms consider the operational realities for providers, particularly small and medium providers delivering direct frontline supports. Any increased compliance obligations should be matched with clear guidance, reasonable implementation timeframes and pricing that reflects the true cost of safe, high-quality support.

If the system becomes too administratively difficult or financially unsustainable, ethical providers may exit the market, reducing participant choice and increasing risk.

Recommendations

Bright Journey respectfully recommends that the Committee:

Ensure the Bill includes strong continuity-of-support protections before any participant’s supports are reduced, paused or removed.

Require the development of a clinically accepted national joint protocol for complex NDIS participants, similar to coordinated practice models used in the out-of-home care sector.

Require genuine co-design with people with disability, families, carers, providers, clinicians and representative organisations before major changes are implemented.

Ensure evidence requirements are fair, accessible and based on functional impact, not just access to specialist reports.

Ensure the NDIA considers provider reports, clinical evidence, incident history, family/carer evidence, allied health reports and participant statements when making complex support decisions.

Target fraud and exploitation without creating unnecessary barriers for legitimate participants and ethical providers.

Ensure mainstream and foundational supports are demonstrably available before participants are redirected away from the NDIS.

Protect review rights, transparency and human rights safeguards in all eligibility, reassessment and funding decisions.

Provide clear implementation guidance and realistic transition timeframes for providers.

Ensure pricing and provider obligations support a safe, skilled and sustainable disability workforce.

Conclusion

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Bright Journey Disability Support Services supports the goal of a sustainable, safe and effective NDIS. However, sustainability must not be achieved by shifting risk onto participants, families, frontline workers or ethical providers.

The NDIS was built to support people with permanent and significant disability to live safer, more connected and more meaningful lives. Reform should strengthen that promise, not weaken it.

Participants with complex needs require more than a funding decision. They require coordinated, clinically informed, cross-system support that clearly identifies responsibility, risk, escalation pathways and continuity of care.

We urge the Committee to recommend that the Bill be amended to include stronger safeguards, genuine consultation, clear evidence standards, continuity of support, a clinically accepted joint protocol for complex cases, and practical implementation measures that protect participants while improving Scheme integrity.

Thank you for considering this submission.

Kind regards,

Sean Rich

Business Development and Intake Officer

Bright Journey Enterprises Pty Ltd

ABN 69687931942

ACN 687931942

NDIS Registration ID: 4-LQKTRD0

Email:

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