Submission 305
Submission 305
About the Australian Chiropractors Association
The Australian Chiropractors Association (ACA) is the peak body for the chiropractic profession in Australia. Chiropractors are 5-year university trained health care professionals. They are one of the fifteen regulated health professions regulated under the National Registration and Accreditation Scheme, working as primary contact practitioners, primarily in community-based settings. Chiropractors manage neuromusculoskeletal conditions through non-pharmacological approaches, including manual therapy (adjustment, mobilisation and manipulation), soft tissue therapies, exercise-based rehabilitation, psychologically informed strategies, and lifestyle advice. The profession collaborates with other healthcare providers, with two-way referral pathways, to ensure optimal clinical outcomes for Australians with neuromusculoskeletal complaints.
Introduction
The Australian Chiropractors Association (ACA) welcomes the opportunity to provide feedback on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 (‘the Bill”).
Australians living with disability, together with their families, carers and support networks, are an important part of the communities’ chiropractors serve every day. People living with disability access chiropractic care across a broad range of settings to support mobility, participation, physical function, independence, comfort and quality of life.
The ACA acknowledges the significant financial and operational pressures facing the NDIS and recognises the importance of ensuring the Scheme remains sustainable for future generations. We are concerned that the scale, complexity and breadth of the proposed amendments, together with the associated explanatory materials and anticipated subordinate rules, have not been matched by adequate time for meaningful consultation, review and consideration by stakeholders.
The Bill proposes substantial reforms to participant access, planning, reassessment, funding and governance arrangements with potentially far-reaching consequences for participants, providers and the broader health and disability ecosystem. The ACA is mindful that progressing such significant reforms within compressed consultation and legislative timeframes increases the risk of unintended consequences, inconsistent implementation and policy settings that may not be sufficiently future proofed for the evolving realities of disability care and support delivery. We also voice concern that the cumulative effect of the proposed amendments risks shifting the NDIS away from its foundational participant-centred principles, including choice and control, individualised supports, community inclusion, dignity and participation.
Additionally, the ACA holds significant concerns about the discretionary powers proposed throughout the legislation, including broad ministerial powers relating to support determinations and funding reductions, together with limited participant-level safeguards and review mechanisms. While the ACA recognises the need for governments to maintain oversight of Scheme sustainability, reforms of this scale should be accompanied by strong transparency, accountability, clinical oversight and consultation safeguards to ensure participant safety, functional outcomes and long-term wellbeing remain central to decision making. There is concern that key decisions affecting participant supports, funding and access may increasingly be vested in administrative or governmental processes without sufficient multidisciplinary clinical input, participant input, or adequate recognition of the complexity and variability of disability presentations.
The ACA is also concerned that the cumulative effect of the proposed reforms may further reduce the already limited access some participants currently have to chiropractic services and other multidisciplinary, function-focused supports within the NDIS. Chiropractors regularly report that participants seek chiropractic care as part of broader multidisciplinary approaches aimed at supporting mobility, participation, physical comfort, functional capacity and independence. Participants themselves frequently identify perceived improvements in day-to-day functioning and quality of life associated with these supports. We are concerned that increasingly narrow interpretations of “reasonable and necessary” supports, combined with more restrictive planning and reassessment frameworks, may unintentionally erode participant choice and autonomy while favouring narrower models of care that may not reflect participant preferences, lived experience or real-world functional outcomes.
Submission 305
The ACA strongly recommends that the Bill is not passed in its current form. We encourage adequate review and consultation time and that any legislative amendment and implementation approaches remain genuinely participant centred, multidisciplinary and sufficiently flexible to recognise the complexity of disability, the variability of the evidence base across disability supports, and the importance of maintaining participant choice, independence and quality of life. The ACA supports evidence-informed decision making and sustainable Scheme reform, however these objectives must be balanced carefully against the risk of creating systems that are overly restrictive, administratively driven or disconnected from the lived realities of Australians living with disability and the practitioners and workforce who support them.
As a member of Allied Health Professions Australia (AHPA), the ACA participates in AHPA’s Disability Working Group. The ACA endorses the broader AHPA submission and associated advocacy regarding the proposed reforms, particularly in relation to framework planning, multidisciplinary clinical input, participant safeguards and the importance of allied health involvement in assessment and planning processes.
Given the breadth of the proposed legislative amendments and limited consultation timeframe, the ACA has focused this submission on those areas most relevant to chiropractic practice, participant outcomes and multidisciplinary disability care.
Submission 305
Schedule 1
Part 1 – Defining Functional Capacity
The ACA acknowledges the intent of the proposed amendments to improve consistency, transparency and equity in how functional capacity is assessed for access to the NDIS.
However, we have concerns regarding how the proposed definition of functional capacity and future assessment thresholds may operate in practice. Chiropractors working with people living with disability frequently observe that functional capacity is dynamic, influenced not only by underlying impairment, but also by pain, mobility limitations, environmental factors, compensatory movement patterns, fatigue, musculoskeletal comorbidities and access to appropriate supports. The proposed emphasis on assessing function “excluding, as far as possible, environmental and personal circumstances” risks underrepresenting the real-world functional challenges experienced by participants, particularly those with complex or fluctuating conditions.
From both a participant and clinical perspective, it will be important that future functional capacity assessment frameworks remain multidisciplinary, person-centred and sufficiently flexible to capture the practical impact of disability on mobility, participation, self-management and quality of life. The ACA would encourage ongoing consultation with disability stakeholders and regulated health professions, particularly allied health, during development of the proposed assessment methodologies and thresholds. Allied Health are the primary professions involved in assessing functional capacity, and as such, should be well represented on the proposed Technical Advisory Group. Clinical judgement by appropriately qualified professionals should not be overridden by administrative processes. This will ensure assessments appropriately reflect the lived experience of disability and do not unintentionally restrict access for participants with significant functional impairment who may not fit narrowly defined assessment criteria.
Part 2 – Plan Reassessment
The ACA recognises the intent of the proposed amendments to strengthen oversight and consistency in participant requested plan reassessments, including ensuring reassessments are linked to genuine and ongoing changes in support needs.
However, the ACA has concerns that the proposed thresholds and conditions for reassessment may unintentionally create barriers for participants with fluctuating, progressive or complex conditions whose functional needs can change over time in ways that may not fit strictly defined criteria. Chiropractors working with people living with disability frequently observe that changes in mobility, pain, balance, functional tolerance, falls risk and capacity for daily activities can occur gradually or episodically. The requirement for changes to be “significant and ongoing” may risk delaying access to appropriate plan adjustments and supports for some participants.
Consideration should also be given to the practical impact of extending the decision timeframe for reassessment requests from 21 to 90 days, particularly for participants experiencing significant changes in functional capacity, mobility or support needs who may require timely adjustments to supports and services.
From both a participant and clinical perspective, it is important that reassessment processes remain sufficiently flexible and person-centred to recognise the realities of disability progression, changing informal supports, and functional deterioration over time. The ACA would encourage careful implementation and ongoing consultation to ensure the reforms improve Scheme integrity without unintentionally limiting timely access to necessary supports or creating additional administrative barriers for participants navigating complex health and disability needs.
Part 3 - Strengthen link between impairment and need for support
The ACA acknowledges the intent of the proposed amendments to improve clarity and consistency regarding the relationship between a participant’s eligible impairment and the supports funded through the NDIS. Greater clarity around the scope of “reasonable and necessary” supports may assist in supporting more consistent decision making and improving Scheme sustainability.
Submission 305
The ACA raises concern that the proposed requirement for supports to arise “directly” from an impairment that meets the disability or early intervention requirements may create unintended barriers for participants with complex, multifactorial or comorbid conditions. Chiropractors working with people living with disability frequently observe that functional limitations, pain, reduced mobility, balance impairment, deconditioning and participation restrictions are often interconnected and cannot always be neatly separated between primary and secondary conditions. For example, a participant with cerebral palsy may also develop secondary musculoskeletal pain, functional deconditioning or reduced mobility over time which, while not independently meeting access criteria, may still significantly impact their independence, participation and day-to-day functioning. A narrow interpretation of supports arising “directly” from an eligible impairment risk excluding supports that help manage these interconnected functional impacts and maintain quality of life.
We caution that an overly narrow interpretation may unintentionally shift participant needs and associated costs into other parts of the health and social care system where equivalent services, funding and supports may not be readily available or accessible. Reduced access to preventative, maintenance and function-focused supports may increase pressure on primary care, hospital systems, informal carers and other mainstream services, particularly for participants with complex or progressive conditions and those in rural and regional areas.
From both a participant and clinical perspective, it is vital that implementation of any reform remains sufficiently person-centred and flexible to recognise the practical realities of disability and the role of multidisciplinary care in supporting mobility, participation, independence and quality of life.
Part 4 Support Determinations
The ACA acknowledges the intent of the proposed support determination measures to improve the long-term financial sustainability of the NDIS and provide government with mechanisms to respond to areas of significant Scheme growth. Measures aimed at maintaining the viability of the Scheme for current and future participants are important and we recognise the need for appropriate stewardship of public funding.
The ACA holds significant concern regarding the broad discretionary authority vested in the Minister through the proposed support determination framework, including the capacity to reduce funding across specified categories of supports through legislative instrument with limited participant-level review mechanisms. While the explanatory materials reference consideration of participant safety, there is limited detail regarding the safeguards, consultation requirements, evidentiary thresholds, independent oversight or impact assessment processes that would inform future funding reductions. The ACA is concerned that broad reductions applied at a category level may have unintended impacts on participants with complex, progressive or high-support conditions who rely on ongoing preventative, maintenance and function-focused supports to maintain mobility, independence, participation and quality of life.
From both a chiropractic and participant perspective, there is also concern that reductions in funding for supports aimed at maintaining function and preventing deterioration may ultimately shift demand and associated costs into other parts of the health and social care system, including hospitals, primary care, aged care, informal carers and other mainstream services that may not have equivalent accessibility, funding or workforce capacity. This may be particularly significant in rural and regional areas where service availability is already limited.
Supports deemed reasonable and necessary should be funded in full. In the absence of such full funding, we encourage consideration of alternative approaches that balance Scheme sustainability with stronger participant safeguards, transparency and stakeholder consultation, particularly where proposed funding reductions may materially affect participant function, safety or access to essential supports. This should include meaningful consultation with participants, disability stakeholders and allied health professions, evidence-informed decision making, clear oversight mechanisms and ongoing monitoring of participant outcomes to ensure cost-containment measures do not unintentionally compromise participant wellbeing, functional capacity or long-term health outcomes.
Submission 305
Part 6 – Reasonable and Necessary Supports
The ACA acknowledges the intent of the proposed amendments to improve clarity, consistency and sustainability in the assessment of “reasonable and necessary” supports under the NDIS. The experience of many chiropractors and participants accessing chiropractic as part of their support arrangements has been one of inconsistent interpretation and decision making. Greater legislative clarity regarding the principles used to determine supports may assist in improving transparency and consistency for both participants and providers.
The ACA raises concerns that a more restrictive interpretation of “reasonable and necessary” supports may unintentionally reduce participant access to preventative, maintenance and function-focused supports that play an important role in maintaining mobility, independence, participation and quality of life. Chiropractors working with people living with disability frequently observe that relatively low-intensity supports aimed at maintaining physical function, mobility, balance, pain management and participation can help prevent functional deterioration and reduce reliance on higher-cost interventions or acute health services over time.
From a participant perspective, we have concern that narrower funding interpretations may disproportionately affect people with complex, progressive or fluctuating conditions whose support needs do not always align neatly with rigid funding frameworks. Reduced access to supports that assist in maintaining function and independence may again, also shift demand and associated costs into other areas of the health and social care system, including hospitals, primary care, aged care and informal carers, where equivalent services and resources may not be readily available or accessible.
The ACA also notes that many decisions regarding “reasonable and necessary” supports ultimately rely on interpretation of clinical evidence, functional impact and participant need within highly complex and individualised disability contexts. However, the disability evidence base is not uniformly developed across all conditions, interventions and support models, particularly in relation to long-term functional maintenance, preventative care, multidisciplinary conservative management and quality of life outcomes. In many areas of disability care, evidence is evolving, varied or difficult to isolate to the level of specificity contemplated within the proposed framework. This is particularly relevant where supports are intended to maintain function, prevent deterioration or support participation, rather than achieve narrowly defined clinical endpoints.
Further, we question the appropriateness of vesting broad interpretative discretion regarding evidence in administrative decision-makers. The ACA is concerned that overly narrow or prescriptive interpretations of evidence may disadvantage participants with complex or less well-studied conditions and may not adequately reflect real world clinical practice, participant experience or lived outcomes.
The ACA advocates for decision-making frameworks that incorporate multidisciplinary clinical input, participant centred considerations and appropriate flexibility in evidentiary interpretation, recognising the practical limitations and variability of the disability evidence base across different conditions and support types.
Schedule 2
We endorse and refer to the issues raised in the submission by Allied Health Professions Australia as representative of concerns of the Australian Chiropractors Association related to Schedule 2 of the proposed legislative amendments.
Schedule 3
We endorse and refer to the issues raised in the submission by Allied Health Professions Australia as representative of concerns of the Australian Chiropractors Association related to Schedule 3 of the proposed legislative amendments.
Submission 305
Schedule 4
The ACA acknowledges the intent of the proposed amendments relating to framework planning and the transition to new framework plans, including measures intended to improve consistency, administrative efficiency and alignment with revised planning and funding arrangements under the NDIS. Greater clarity and consistency within planning processes may assist participants and providers to better understand how supports are assessed, funded and reviewed over time.
The ACA endorses the position of Allied Health Professions Australia (AHPA) regarding the development and implementation of new framework planning arrangements and associated support needs assessments. We share concerns regarding the limited parliamentary scrutiny proposed for the future rules underpinning framework planning, despite these rules having significant implications for participant plans, assessment processes and budget setting. The ACA strongly supports the need for allied health input, reports and multidisciplinary clinical expertise to be appropriately incorporated into support needs assessments and planning decisions. Allied health professionals play a critical role in assessing functional capacity, participation needs and long-term support requirements for people living with disability.
From both a participant and clinical perspective, it will be important that framework planning processes remain sufficiently person-centred, multidisciplinary and responsive to real-world functional outcomes. Chiropractors working with people living with disability frequently observe that participant needs can vary significantly over time and may not always align neatly with standardised planning assumptions or rigid funding structures. There is concern that overly prescriptive planning approaches, or broad reductions in funding beneath assessed levels of need, may unintentionally reduce participant access to supports that maintain mobility, independence, participation and quality of life.
We advocate for implementation approaches that preserve flexibility for individual circumstances, ensure appropriate clinical expertise informs planning decisions, and maintains transparency, safeguards and meaningful stakeholder consultation throughout the ongoing development of the framework planning rules.
Concluding Comments
We again thank the Senate Community Affairs Legislative Committee for the opportunity to provide feedback on the
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. The ACA
reiterates its position that the Bill should not proceed in its current form. We emphasise the need for meaningful, transparent and appropriately considered consultation on legislative reform of this scale, complexity and significance to Australians living with disability, their families and the broader disability support sector.