1 July 2026
Committee Secretary
Senate Standing Committee on Community Affairs
PO Box 6100
Parliament House
Canberra ACT 2600
By online submission: aph.gov.au
Re: Submission — National Disability Insurance Scheme Amendment (Securing the NDIS for Future
Generations) Bill 2026
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 NDIS
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.
- 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.
We recommend this power be removed, or at minimum, that any determination be preceded by published
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,
particularly 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.
- 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.
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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