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

Committee Secretary Senate Standing Committee on Community Affairs PO Box 6100 Parliament House Canberra ACT 2600 By online submission: aph.gov.au

To the Committee,

This submission is made by Accessing Connections Support Services, a boutique mobile Support Coordination and Psychosocial Recovery Coaching provider based in Greater Geelong region, Victoria. We support NDS participants living with complex mental health conditions, psychosocial disability, and cognitive, physical, and intellectual disabilities, working alongside individuals, families, carers, and clinical professionals to connect participants with the supports and services that best meet their needs.

We support the intent of ensuring the long-term sustainability and integrity of the NDIS. However, we are concerned that several provisions of this Bill would reduce access to reasonable and necessary supports in ways that shift risk and cost onto participants, families, and the broader service system, rather than genuinely reforming the Scheme. We ask the Committee to consider the following concerns, drawn directly from our day-to-day work with participants.

1. Ministerial power to reduce funding for groups of supports (Schedule 1, Part 4)

The Bill would allow the Minister to make determinations reducing funding for entire categories of supports, including social, civic and community participation, and capacity-building daily activities, without requiring an individualised assessment of the impact on each affected participant. In our experience, these support categories are frequently the difference between a participant maintaining community connection and independence, and a participant becoming isolated or reliant on crisis or institutional responses. A blanket, category-wide funding reduction cannot account for the individual circumstances the NDIS Act was built to protect.

impact analysis, genuine consultation with affected participants and providers, and a requirement that the Minister be satisfied no material risk of harm, isolation, or loss of independence will result.

Narrowing of the link between supports and eligible impairment (Schedule 1, Part 3)

The Bill would restrict funding to supports where the need arises directly from the impairment for which a participant met NDIS access criteria. Many of the participants we support have complex, co-occurring presentations, for example, psychosocial disability alongside physical or cognitive impairment, where support needs cannot be neatly attributed to a single, originally-assessed impairment. A narrow, impairment-specific test risks excluding legitimate and necessary support needs simply because of how a participant’s original access decision was framed, rather than their actual current circumstances.

We recommend reasonable and necessary supports continue to be assessed on a holistic basis, reflecting the participant’s overall functional impact, rather than a narrow causal test tied to their original access category.

Impact on the Support Coordination sector itself

We note that the Government’s own Impact Analysis identifies a preferred option to replace the current Support Coordination market with a newly commissioned service subject to capped program expenditure. As a small, independent, mobile Support Coordination provider operating in a regional area, we are concerned this would significantly reduce participant choice and control, a foundational principle of the NDIS, and could make it commercially unviable for boutique, locally-based providers like ours to continue operating, especially in regional and remote communities already underserved by larger providers.

We recommend that any reform to Support Coordination preserve genuine participant choice of provider, avoid expenditure caps that would reduce the availability of coordination services in regional areas, and include a proper transition and consultation process for existing providers before any new model is commissioned.

Cost and viability impact of expanded registration requirements on small providers

The Bill expands mandatory provider registration over the coming years, adding to compliance, audit, and administrative obligations that fall disproportionately hard on small, independent providers such as ours. As a sole/small operator, the time and cost of meeting registration, evidencing, and reporting requirements is not absorbed the same way it might be by a large, well-resourced organisation with dedicated compliance staff; it comes directly out of the hours we would otherwise spend supporting participants, and out of a business that is already operating on Support Coordination pricing that has not increased in seven years.

We are particularly concerned that providers are being asked to invest in meeting new and increased registration requirements for a market the Government has already signalled it intends to replace with a centrally commissioned panel by mid-2028. Being told our market is being abolished while being asked to pay

more to remain compliant within it in the meantime is an unreasonable burden, and a real risk to the survival

of small, regional, and boutique providers between now and any transition. If small providers are forced to

close or exit before a commissioned model exists, participants lose their existing provider relationships and

are left with fewer choices in the interim, the opposite of the choice and control the NDIS was built on.

Speaking from our own experience: the cost and uncertainty created by this reform pathway is already making

it difficult for us to plan and grow our business with any confidence. I have worked as a Support Coordinator

since 2016, and I have held off on formally registering as an NDIS provider since 2023 because of the

uncertainty created by this reform pathway, it has been genuinely difficult to justify the cost and

administrative commitment of registering for a market I have been told will be replaced within a few years.

In the meantime, I maintain an active caseload of participants who rely on this service, and who would be

directly and significantly affected if I were forced to reduce or cease operating before any replacement model

exists. Decisions that a small provider needs to make to build a sustainable service, investing in staff, systems,

premises, or new service offerings, depend on having some certainty about what the market will look like and

what it will cost to operate in it. Not knowing whether, or on what terms, we will still have a viable business

by 2028 makes it very difficult to justify that investment now, even though participants in our region need the

service today. This is not a hypothetical concern; it is actively shaping how we plan our business in the present,

and we do not believe we are alone in this among small providers.

We recommend the Committee consider a freeze or waiver on new and increased registration costs for

Support Coordination and Plan Management providers until the design of any commissioned panel model is

finalised, along with staged, proportionate compliance requirements and exemptions or simplified pathways

for small providers and thin markets, consistent with recommendations already put forward by disability

representative organisations.

This is not a new concern. The Joint Standing Committee on the NDIS’s own Workforce Interim Report, tabled

in the last Parliament, identified the inadequacy of current NDIS prices as a headline issue and recommended

the Government facilitate an independent review of the Scheme’s funding model. Separately, the sector’s

peak body, National Disability Services, ran a dedicated campaign in 2024 highlighting that Support

Coordination pricing had already been frozen for five years at that point, warning that providers were leaving

the sector as a direct result, and calling on the NDIA to provide fair, sustainable funding for Support

Coordination. Parliament and the sector have already identified that Support Coordination is a vital function

that was, if anything, in need of increased investment to remain viable. This Bill and its associated reform

package move in the opposite direction, extending the price freeze, adding registration costs, and ultimately

capping program expenditure altogether, without the funding review previously recommended having

occurred.

5. Timeframe for consultation

Given the scale and consequence of these changes for participants who rely on the Scheme daily, we are concerned that the timeframe for this inquiry has not allowed for full and accessible consultation with people with disability, their families, and the providers who support them. We support calls from disability representative organisations for the Bill’s progression to be paused until further evidence, modelling, and genuine co-design has occurred.

Summary of recommendations

Remove, or substantially constrain, the Ministerial power to reduce funding for categories of support without individualised impact assessment.
Retain a holistic, whole-of-person assessment of reasonable and necessary supports rather than a narrow impairment-specific test.
Ensure any reform to Support Coordination preserves participant choice of provider and does not disadvantage small, regional, and boutique providers.
Freeze or waive new and increased registration costs for Support Coordination and Plan Management providers until the commissioned panel model is finalised, and introduce staged, proportionate compliance requirements for small providers.
Extend consultation timeframes to allow genuine, accessible engagement with people with disability and the sector.

Thank you for the opportunity to contribute to this inquiry. We would welcome the opportunity to provide further information or give evidence to the Committee if that would assist.

Yours sincerely, Nicola Fenton Accessing Connections Support Services admin@accessingconnections.com.au | 0420 307 060