Submission 3050 — Ms Shannon Manning — NDIS Future Generations Bill

SUBMISSION TO THE SENATE COMMUNITY AFFAIRS LEGISLATION COMMITTEE

National Disability Insurance Scheme

Amendment

(Securing the NDIS for Future Generations) Bill 2026

Submission opposing the Bill in its current form and addressing its impact on families living with lifelong, significant and permanent disability

I support a sustainable, safe and trustworthy NDIS. I oppose this Bill in its current form because it creates broad mechanisms to restrict access and funding, transfer support obligations to families, and make high-impact decisions through rules, instruments and administrative systems that are not yet fully designed or publicly tested. The Committee should recommend that the Bill not be passed in its current form. It should be withdrawn or substantially redrafted through genuine co-design with people with disability, families and representative organisations.

Inquiry National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

Committee Senate Community Affairs Legislation Committee

Submitted by Shannon Manning

Capacity Mother

State or Territory Queensland

Email

Telephone

Publication request Public with my name

Date 10 July 2026

Oral evidence I request permission to speak to this submission and to appear and give oral evidence. Details are set out below.

Editable submission - replace highlighted fields before lodging

REQUEST FOR PERMISSION TO SPEAK AND GIVE ORAL EVIDENCE

I respectfully request the Committee’s permission to speak to this submission and to appear at any further public hearing. I can give firsthand evidence about life before the NDIS, the continuing burden on a family supporting children with lifelong, significant and permanent disabilities, and the cumulative effect of this Bill. I am available by videoconference.I consent to the Committee Secretariat contacting me using the details above. I would also address the proposed transfer of unmet need to hospitals and health departments, the tax treatment of NDIS-funded provider income, and why Australia should preserve a national social insurance model rather than return to fragmented responsibility.

Scope note: This submission addresses the provisions and foreseeable operation of the Bill. Personal experience is used to explain systemic impact. It does not ask the Committee to determine an individual NDIS plan, complaint or review. Currency note: This submission addresses the Bill as introduced on 14 May 2026 and the Government amendments agreed in the House of Representatives on 1 July 2026, as summarised by the Department of Health, Disability and Ageing on 2 July 2026. The Bill remains subject to parliamentary amendment.

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Contents

• 1. Executive summary
• 2. Recommendations
• 3. About my family and why this Bill matters
• 4. What the Bill will mean for families like mine
• 5. Detailed submission on the Bill
• 6. Human rights and statutory principles
• 7. A safer and more credible path to sustainability
• 8. Request for permission to speak and give oral evidence
• 9. Conclusion

• Appendix A - Clause-to-recommendation index

• Appendix B - Personalisation and filing checklist

• References I am a parent of children with lifelong, significant and permanent disabilities. For my family, the NDIS is not an optional benefit and disability support is not a discretionary lifestyle expense. Properly funded support is the practical infrastructure that makes safety, communication, personal care, relationships, education, community participation and ordinary family life possible. My children were diagnosed before the NDIS existed and were supported under the former disability services system. I therefore know firsthand what Australia was like for families before the NDIS: fragmented responsibility, rationed services, uncertainty and relentless advocacy. When the NDIS began, I thought - stupidly, as it now feels - that I would no longer have to keep fighting; that my children would be safe and would have the support required for a genuine quality of life. Instead, one of the principal things I have learned is how to fight: for recognition of obvious lifelong disability, for adequate plans, for suitable services, for continuity and for basic security. I want to be happy again. I am constantly under pressure, chronically burnt out and always worried that, simply because my children were born disabled, I must keep fighting for what they need. Australia is known as the Lucky Country. We say we are fair dinkum and that everyone deserves a fair go. Those words must have practical meaning for people born with significant and permanent disability. A fair go cannot mean lifelong insecurity for the disabled person and permanent exhaustion for the family. My children are the future generations named in the Bill’s title. They are not a legacy cost from the past and they are not an administrative problem to be moved elsewhere. They will live with the consequences of this law for the rest of their lives. A Bill cannot credibly claim to secure the NDIS for future generations if it makes the disabled children who are those future generations less secure now. We are not the United Kingdom, with disability responsibility divided among different systems, including England’s SEND and Education, Health and Care plan framework for children and young people. We are not the United States, where disability supports are distributed across insurance, federal programs, state administration and optional benefits. Those systems are not direct equivalents to the NDIS, but Australia should not import their most feared features: fragmentation, gatekeeping, postcode or jurisdictional variability, cost-shifting and repeated conflict. We are Australia. We created a national social-insurance scheme and should strengthen that Australian model, not dismantle it by degrees. [12]-[14] I support measures that prevent fraud, unsafe services, conflicts of interest, price exploitation and misuse of public funds. I also accept that Parliament must consider long-term financial sustainability. However, sustainability is not achieved merely by moving cost and responsibility out of the NDIS ledger. When funded supports are removed or made inaccessible, the need does not disappear. It is transferred to disabled people, parents, partners, siblings, ageing carers, hospitals, schools, housing services, child protection systems and crisis services. Australia’s public health system is already under severe pressure. In 2024-25, Australian public hospital emergency departments recorded 9.1 million presentations; only 53 per cent of presentations were

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completed within four hours, and only 30 per cent of presentations ending in admission were completed within four hours. [15] To remove people from the NDIS or reduce the supports that keep them safe at home, then expect hospitals and health departments to pick up the resulting need is, frankly, insane. It is also fiscally reckless: disability-support costs do not disappear when moved into emergency, inpatient, mental health or crisis systems. Fiscal scrutiny must also apply to organisations earning revenue from participant plans. Every dollar leaving the NDIS as a provider payment should be traceable, reportable and visible to taxation and regulatory authorities. Commercial NDIS-derived income should not receive preferential tax treatment merely because the provider is structured as a charity, church or not-for-profit. This is not a proposal to tax participants or reduce their plan budgets; it is a proposal for provider-side tax neutrality and public money accountability. [16]-[18] Parliament’s own remuneration arrangements illustrate the same accountability principle. Under the determination in force from 1 July 2025, every senator and member of the House of Representatives receives a base electorate allowance of $39,700 a year, with higher amounts for geographically larger House electorates. The ATO requires parliamentary allowances generally to be returned as assessable income, while deductions are available only for eligible expenses actually incurred. [26] The Bill is not a narrow integrity measure. It changes the architecture of access, planning and funding. It enables standardised functional capacity assessments, tighter access and permanence tests, narrower links between impairment and supports, restricted unscheduled reassessment, plan end dates without carryover, cohort-level reductions to specified support categories, greater reliance on scheme sustainability and cross-participant equity in individual funding decisions, suspension and possible revocation after failed contact, expanded participant record-keeping and debt consequences, a 90-day claims limit, Ministerial pricing, automation of administrative action, and broad rule-making for new framework planning. [2] The Government amendments agreed on 1 July 2026 improve some procedural detail, including minimum contact attempts, clarification of publicly funded treatment, publication of certain automated arrangements, a 2029 review and additional pricing transparency. They do not cure the central problems. The power to reduce whole categories of support remains. The new access and planning architecture is still enabled before the assessment methods, thresholds, rules and incorporated documents are fully known. The review occurs after several years of possible harm. [3] The fiscal context matters. The Parliamentary Library records that the reform program is intended to reduce projected NDIS expenditure growth by $37.8 billion over four years. It also records Government modelling of approximately 600,000 participants by the end of the decade, compared with 774,456 participants at 31 March 2026. On its face, that is about 174,000 fewer participants than were already in the Scheme, before population growth. The same analysis records an intended reduction in average social and community participation spending from about $31,000 to about $26,000 over two years. These figures make it essential that Parliament scrutinise who is expected to lose access or support, what alternatives will actually exist, and who will absorb the resulting work and risk. [5] The current NDIS Act expressly links the Scheme to the Convention on the Rights of Persons with Disabilities and requires support for independence, social and economic participation, reasonable and necessary supports, choice and control, lifetime certainty, inclusion, family relationships and individualised planning. Financial sustainability is an important statutory consideration, but it is not the sole object of the Act. [6] My family’s experience also demonstrates a form of waste that the Bill does not solve. We repeatedly obtain lengthy and costly assessments to re-prove significant, lifelong and permanent disability. The Agency demands clinical and medico-legal reports, yet delegates may fail to engage with their central findings, focus on isolated wording or require the family to repair practitioner errors. That is not fiscal responsibility. It spends public and participant money producing evidence, then fails to use it. The same pattern affects approved safeguards. The NDIA approved home modifications for our family before a Positive Behaviour Support Plan was in place. We now have a plan that further identifies safeguarding issues, yet the process has generated further demands for reports, quotes and re documentation rather than a coordinated path to completing the approved modifications. Necessary

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building due diligence is legitimate; serial and shifting demands that duplicate what is already known are not.

Core submission The Bill should not pass in its current form. Any replacement Bill must preserve individualised entitlement, continuity of essential supports, informed consent, procedural fairness, merits review, transparent and validated assessment, protection from automated harm, and a clear rule that families are not the default unpaid substitute for disability support. Substantive access criteria, funding restrictions and assessment methods should be in the Act or disallowable instruments, not left to changeable administrative documents. No reduction should occur until replacement supports are operational, accessible, adequate and independently evaluated. Any claimed saving must include costs transferred to families, hospitals and other public systems. Fiscal scrutiny should also apply to provider-side NDIS income and tax concessions, not only to participant entitlement.

Recommendations

I ask the Committee to make the following recommendations. The first recommendation is primary. The remaining recommendations are minimum safeguards if Parliament nevertheless decides to proceed.

1. Do not pass the Bill in its current form. Recommend withdrawal or substantial redrafting after genuine, accessible co-design and publication of the complete evidence base, modelling, assessment architecture, draft rules and human rights analysis.

2. Sequence reform lawfully and safely. Do not commence substantive access, support reduction, new planning or reassessment powers until all rules, instruments, assessment tools, thresholds, training standards and operational guidance are published, independently tested and subject to parliamentary scrutiny.

3. Protect existing participants with established lifelong disability. Do not require repeated proof that a clearly lifelong impairment remains permanent. No current participant should lose access solely because of a standardised tool. Existing supports must continue until all internal and external review rights are exhausted.

4. Use a whole-person, social-model functional assessment. Assessment must consider environmental barriers, communication, fluctuating and episodic disability, interacting impairments, supported versus unsupported functioning, cultural context, risk, and the consequence of withdrawing support. Treating evidence and participant evidence must be given genuine weight.

5. Publish and validate all assessment methods. Publish the tool, scoring, thresholds, data sources, training materials, reliability and bias testing, disability-specific validation and change history. Pilot independently before national use and provide accessible reasons for every result.

6. Restore a broad and rapid unscheduled reassessment pathway. Permit reassessment for urgent safety risk, health change, housing instability, family breakdown, provider failure, bereavement, school or work exclusion, exploitation, underfunding and other material changes. Emergency variations should be available within 48 hours and ordinary requests decided within 21 days.

7. Replace the narrow direct-impairment test. A support should be fundable where the need arises from, is materially related to, or results from the interaction or secondary effects of an access impairment. Decision makers must assess the person as a whole rather than fragmenting disability into administrative categories.

8. Delete the support determination power. The Minister should not be able to reduce funding across specified groups or support categories. If the power is retained, it must not reduce a participant below individually assessed reasonable and necessary need and must include evidence thresholds, co-design, rights and safety impact assessment, hardship exemptions, individual merits review, parliamentary disallowance and a sunset clause.

9. Remove or tightly confine the parental responsibility presumption. The Act must distinguish ordinary age-related parenting from disability-specific supervision, personal care, transport, behavioural support and communication support. It must consider the sustainability, health, employment and safety of parents and siblings and must never treat family availability as unlimited capacity.

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10. Preserve individualised reasonable and necessary support. Scheme sustainability and cross-participant equity must not operate as an overriding fiscal cap in an individual decision. Comparable treatment should be a floor of fairness, not a ceiling that prevents a person from receiving support for their actual needs.

11. Guarantee seamless plan continuity and carryover. A renewed plan must commence before the old plan ends, preserve booked and legally committed supports, and carry forward funds where underspend reflects episodic need, hospitalisation, provider failure, thin markets, delayed equipment or home modifications, or other matters outside the participant’s control.

12. Treat failed contact as a safeguarding issue, not abandonment. No participant status should be revoked merely because contact has failed. Require active safeguarding, contact through nominees and advocates, review of known circumstances, accessible communication, welfare checks where appropriate, continuation of essential supports and automatic reinstatement without a new access process.

13. Protect bodily autonomy in the permanence test. No person should be disadvantaged for declining treatment. Treatment must be clinically appropriate, evidence-based, safe, acceptable to the person, realistically available, affordable and capable of materially improving the impairment. Waitlists and geographic barriers must be considered.

14. Prevent gaps between the NDIS and other systems. The NDIS may rely on another system only where the alternative support is legally enforceable, timely, adequate, accessible and actually available. Hospitals and health departments must not be treated as default providers of daily disability support. NDIS support must continue until a safe handover occurs. Jurisdictional funding disputes must not be imposed on the person.

15. Make integrity measures proportionate and disability-responsive. Participant record-keeping obligations must include accessible assistance, reasonable-excuse provisions, protection where a nominee, provider or system caused the failure, and no debt unless the person received an amount to which they were not substantively entitled. Good-faith administrative error must not be equated with fraud.

16. Extend the 90-day claims period. Use at least 12 months, with mandatory extensions for disability, hospitalisation, family violence, bereavement, provider delay, nominee failure, technology failure and other reasonable causes.

17. Use risk-proportionate provider regulation. Support mandatory registration where risk justifies it, while preserving self-management and trusted small or sole providers through staged transition, grants, simple compliance pathways and safeguards against market exit in regional, remote and specialist markets.

18. Preserve choice of plan manager and continuity. Any commissioned panel must include transparent eligibility, participant choice, conflict safeguards, cultural and regional accessibility, and transition arrangements that do not sever trusted relationships.

19. Create independent and transparent pricing governance. Pricing should be based on published evidence and independent advice, with explicit allowance for complex support, training, supervision, travel, regional and thin markets, worker conditions and inflation. Underpricing must not become hidden rationing through provider withdrawal.

20. Prohibit automated adverse decisions. Automation should be limited to low-risk clerical processing. Eligibility, budgets, support reductions, suspensions, revocations, debts, compliance sanctions and disputed claims must be decided and signed off by a human. Every person must be told when automation was used and receive meaningful reasons and rapid human review.

21. Constrain new framework planning powers. Core entitlement criteria and budget logic must be in primary legislation or disallowable instruments. Do not permit substantive rules to incorporate NDIA documents as changed from time to time. Participants must have access to the full assessment record, calculation method and review rights.

22. Require replacement supports before NDIS reductions. Foundational or mainstream supports must be operational, funded, available in the person’s location, accessible, culturally safe and independently evaluated before any NDIS access or funding reduction depends on them. Continuity and no-detriment guarantees must be statutory.

23. Review early, publish data continuously and include a stop mechanism. Do not wait until 2029. Require independent reviews at 12 and 24 months, quarterly disaggregated reporting, participant-led monitoring, and a power to pause measures where access loss, service gaps, crisis, institutionalisation, family breakdown or discriminatory impact emerges.

24. Fund advocacy and legal assistance. Provide additional independent advocacy, decision support and legal assistance before commencement and throughout reassessment and transition. Supports must continue pending review so that a successful appeal is meaningful.

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25. Require a family and carer impact statement. Every rule, determination and assessment change should include an analysis of unpaid care, employment, health, gender, children, siblings, ageing carers, rural and remote communities, First Nations people, culturally and linguistically diverse communities and people with communication or cognitive disability.

26. Grant permission for lived-experience evidence. Invite me and other directly affected participants and families to speak to our submissions and give oral evidence, including remotely and with support people, communication assistance and other reasonable adjustments, before the Committee finalises its report.

27. Require whole-of-government cost and capacity modelling. Before any access or funding reduction commences, publish Commonwealth, state and territory modelling of the effects on hospitals, health and mental health services, education, housing, justice, child protection, income support, carer employment and unpaid care. A measure must not commence unless any receiving system is legally responsible, funded, staffed, accessible and operational.

28. Apply tax neutrality to NDIS-funded provider income. Every provider payment from a participant plan must be traceable and reported. Fee-for-service income and commercial surplus derived from NDIS plans should be subject to equivalent effective taxation regardless of whether the entity is for-profit, charitable, religious or not-for-profit. Donations are one thing; taxpayer-funded service revenue is another. Parliament should remove status-based tax arbitrage or impose an equivalent NDIS public-money levy. Participants’ plan funding must not be taxed, and the reform must not reduce their supports.

29. Preserve Australia’s national social-insurance model. Do not replace individualised national entitlement with fragmented, state-dependent, school-dependent, health-system, insurance or charity-based gatekeeping. The NDIS should remain an Australian national response to permanent and significant disability, grounded in a fair go and shared national responsibility.

30. End repetitive proof of established permanent disability. Once permanent impairment and lifelong functional impact are established, record them in a durable evidence passport. Review changing support needs, not whether the disability still exists. The Agency must identify the precise material issue requiring an update, accept relevant longitudinal and medico-legal evidence, prohibit routine annual or twelve month re-proof, and pay the reasonable cost of any new assessment it requires.

31. Legislate evidentiary procedural fairness and report-quality safeguards. Delegates must read and engage with material reports, identify what is accepted or rejected, explain any conflict and seek clarification before an adverse decision. An isolated drafting error, ambiguity or omission must not be treated as proof of lesser disability or need. Participants must receive notice of the issue, a reasonable no cost opportunity to correct it, assistance to address practitioner error and continuity of support while it is resolved. The Agency should maintain a report-quality pathway with appropriate referrals to the NDIS Quality and Safeguards Commission, professional regulators or complaints bodies instead of leaving participants to fight alone.

32. Complete approved home modifications through one coordinated safeguarding pathway. Where the Agency has already approved or accepted the need for home modifications, later behaviour-support or safeguarding evidence should inform and accelerate delivery, not restart the case. Give the participant one written schedule of necessary assessments, design documents and quotes; prohibit serial or duplicative requests; recognise previously supplied evidence; impose decision and implementation timeframes; fund repetition caused by Agency delay or changed requirements; and maintain interim safeguards.

33. Strengthen COAG-style intergovernmental disability accountability. Use the existing Disability Reform Ministerial Council and, where cross-portfolio authority is required, National Cabinet and First Ministers to restore visible shared responsibility. Publish responsibilities, service capacity, agreements, communiques, implementation data and unresolved interface disputes. Include people with disability and families in governance, adopt enforceable no-wrong-door protocols and prevent Commonwealth-state disagreements from interrupting support. The mechanism may carry any name, but it must provide the transparent national accountability families associated with COAG.

My children were diagnosed before the NDIS and were supported through the disability-services arrangements that preceded it. I know firsthand what it was like before the Scheme: families were required to navigate fragmented programs, limited service places and uncertainty about whether essential support would be available at all.

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When the NDIS was introduced, I thought - stupidly, as it now feels - that I would not have to continue fighting in the same way. I believed my children would be safe and could have a genuine quality of life. Instead, all I have learned is how to fight: how to assemble evidence, explain the same permanent disability again, challenge inadequate decisions, search for services and hold together the consequences when the system fails.

My children live with rare, lifelong and permanent disabilities My daughter, has a profound, lifelong and permanent intellectual impairment. She has Level 3 autism requiring very substantial support and is pre-verbal/non-verbal (non-speaking). She also has Phelan McDermid syndrome, a rare genetic neurodevelopmental disorder. Specialist European guidance estimates an incidence of at least 1 in 30,000 in European countries and considers underdiagnosis likely; GeneReviews states that the true prevalence remains unknown. The condition is commonly associated with absent or severely delayed speech and moderate-to-profound intellectual disability. [24] These are not labels that expire at the end of a plan. They describe permanent impairment and support needs that remain present every hour of every day. My son lives with Cantú syndrome, an exceptionally rare genetic disorder whose incidence is unknown. GeneReviews reports that more than 100 people had been molecularly identified in the published evidence on which its review is based, and describes a condition that can require continuing multi-system medical monitoring. [25] His individual disability needs must be understood from his own evidence. The rarity of both genetic conditions means that a planner or generic assessor may never previously have encountered them. Rarity does not make the needs doubtful. It makes specialist evidence more important, not less. My daughter is almost 15 years old and physically the size of an adult. I still change her nappies and provide all of her continence care. I dress her, feed her, bathe her, support her communication, supervise her safety and assist her with every part of daily life. In the intensity and constancy of hands-on assistance, the care resembles that required by a one-year-old, but it is being provided to an adult-sized adolescent and must be sustained year after year. That comparison describes the level of assistance, not my daughters personhood, age, preferences or dignity. She is an almost 15-year-old person and is entitled to be respected as such. This care does not pause because I am tired, unwell, injured, completing NDIS paperwork or dealing with another crisis. It includes intimate personal care, cleaning, laundry, meal preparation, physical assistance, communication support, constant supervision and vigilance for risk. Because my daughter is adult-sized, the physical demands are not comparable to ordinary care of a small child. This is continuous disability specific work. At the same time, my son has his own disability, health, appointment, monitoring and support needs arising in the context of Cantú syndrome. His needs do not stop while I am caring for my daughter, and her needs do not stop while I am caring for him. When both children need me, there is no fair or harmless choice. When I choose one child’s immediate need, I feel that I am letting the other one down. I am always triaging - deciding which risk, distress, appointment or essential task must come first and which child must wait. That is not a failure of love or organisation. It is the mathematical reality that one person cannot perform two sets of complex, urgent and lifelong care at the same time. The phrase “parental responsibility” can conceal this reality. It can sound as though there is an ordinary reserve of family care that government may safely draw upon. There is no reserve. Every additional hour transferred from funded support to our family must be taken from another child, sleep, health, paid work, friendship, advocacy or the basic tasks required to keep the household functioning. I do not have the same ordinary Australian life that other people are able to take for granted. I have not attended a birthday party in ten years. I do not get to see my friends. I have not been to a cinema in more than ten years. I cannot simply get my hair done, get my nails done, meet somebody for a coffee, take a mental-health day or do the small ordinary things through which adults maintain friendships, identity and wellbeing. These are not extravagant luxuries. Their absence is prolonged social isolation. My life is constant support, supervision, personal care, coordination, appointments, paperwork, advocacy and contingency planning. Even when nothing has gone wrong, I am preparing for what might. When funded support is cut, delayed or made uncertain, the missing work does not disappear. It is transferred to

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me. The consequence is greater physical strain, isolation and burnout, and less capacity to be my children’s parent rather than a permanently on-duty unpaid disability workforce. The disability-specific supports required by my children do not replace family love, parenting or relationships. They make those relationships possible and sustainable. They provide the trained assistance, safeguarding and continuity that no family can supply without limit, and they allow my children to live with dignity, participation, choice and control. Our family already contributes substantial unpaid care, coordination, advocacy, monitoring, emotional support and contingency planning. We fill gaps when workers cancel, services are unavailable, equipment fails, systems disagree about responsibility or a plan does not reflect actual need. The existence of family support is not evidence that formal support is unnecessary. It usually shows that the family has absorbed a system shortfall at serious personal cost. This is why the relevant question is not whether I love my children or whether I will care for them. I do, and I will. The question is whether government will use that love as a limitless substitute for properly funded disability support. IT MUST NOT. I am constantly under pressure, chronically burnt out and always worried about what will happen if I cannot keep fighting. I want to be happy again. I want to be my children’s parent, not their permanent unpaid service system, case manager, advocate and crisis response. A fair disability system should not require a family to sacrifice its health and peace simply because its children were born disabled. For a person with lifelong disability, certainty is itself a safeguard. Constant re-proving of disability, repeated assessment by unfamiliar people, unpredictable plan expiry, fear of category-wide reductions and the possibility of losing access after administrative contact failures create chronic insecurity. Families cannot plan housing, work, education, care arrangements, worker recruitment or ageing-carer transitions when the legal foundation of support is repeatedly reopened. A person may appear to have greater functional capacity precisely because their supports are working. Communication devices, routines, prompting, trusted workers, accessible transport, behaviour support and family scaffolding can make participation possible. An assessment that measures supported performance but assumes the support is unnecessary confuses the effect of support with the absence of disability. Removing support does not reveal hidden independence. It can remove the conditions that made independence possible. I also know firsthand the evidentiary treadmill. Although my children’s disabilities are significant, permanent and lifelong, our family has repeatedly been required - in practice, often at roughly twelve month intervals - to obtain updated functional assessments, specialist reports and medico-legal documents to prove facts that have not changed and cannot change. Each assessment carries a substantial direct cost, consumes scarce clinical time and can use funds that should be buying actual support. The cost is not only financial. The appointments take hours. Comprehensive assessment requires me to answer detailed questions across every domain of my children’s lives and requires practitioners to spend many further hours analysing and writing. It is re-traumatising. I am forced to confront, yet again, that my children will never be independent without substantial support, will always be vulnerable and will always require assistance across every domain of life. They can still exercise choice, participate and have meaningful lives, but only with the right support. What makes this particularly unreasonable is that the Agency demands these reports but delegates do not always understand, acknowledge or apply them when deciding funding. Reports can be treated as documents to search for an error, inconsistency or isolated phrase rather than as evidence to help the Agency reach the correct decision. The Agency should be helping, not harming. It should ask what a report establishes, clarify any genuine uncertainty and apply the evidence to the statutory criteria. When a practitioner writes a poor, incomplete or inaccurate report, the participant is commonly left to challenge the practitioner, pay for correction, commission another report and then fight the Agency as well. The person whose disability is in question did not write the report, yet they pay the price through reduced or delayed support and a life made harder than it needs to be. A badly written report must not become a badly funded life. The Agency, Commission and relevant professional regulator should carry an active quality-control and remediation responsibility.

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Our home modifications show the same failure of coordination. The NDIA approved home modifications before we had a Positive Behaviour Support Plan. We now have that plan, and the Agency is plainly on notice of the safeguarding issues. Instead of bringing the approved safeguard to completion through one accountable process, the family has faced further demands for reports, quotes and more evidence. I accept that complex building work requires proper assessment, design and pricing. I do not accept moving goalposts, duplication or making evidence expire through delay. That is throwing good money after bad. Bill Shorten spent time seeing a day in our family’s life, and around that period the home modifications were approved. I do not suggest that a ministerial visit should be necessary or that it replaces lawful decision-making. The opposite is true: no family should need ministerial attention before practical risk is understood. I invite any parliamentarian considering this Bill, subject to my children’s consent, privacy and safety, to spend a full day seeing what reasonable and necessary support means in practice.

What the Bill will mean for families like mine

The following impacts are foreseeable consequences of the powers and processes created by the Bill. They are not claims that every family will experience every outcome. They are risks that Parliament should address before conferring the powers.

This Bill tests Australia’s promise of a fair go. Australia’s national character is often expressed through the idea of the Lucky Country, being fair dinkum and giving everyone a fair go. For people with lifelong disability, a fair go requires more than equal words. It requires the disability-specific support needed to exercise ordinary rights and live an ordinary life.

My children are the ‘future generations’ in the Bill’s title. The title is deeply insulting if security for an abstract future is purchased by making disabled children living now less secure. My children are the future generations. They will become disabled adults and will depend on the legal architecture Parliament creates today. Their safety, participation and quality of life cannot be treated as a short-term cost problem standing in the way of somebody else’s future. Australia should not drift toward the fragmented features seen overseas. England’s SEND and Education, Health and Care plan system is an education framework, and the United States uses a mixture of insurance and federal and state programs; neither is a direct substitute for the NDIS. [12]-[14] The lesson is that fragmentation creates boundaries, delays and fights about who is responsible. Australia created the NDIS precisely because the pre-NDIS system was fragmented, inequitable and uncertain. Recreating those conditions would be regression, not reform.

Lifelong uncertainty instead of lifetime certainty. Current participants are to be progressively reassessed under new functional capacity arrangements from 1 January 2028. [4] Families with clearly lifelong disability may again have to prove eligibility through methods that are not yet fully known. This reverses the practical promise that support can be planned across a lifetime.

Re-proving permanent disability is waste, not integrity. Support needs can change and may properly be reviewed. The underlying lifelong disability should not be re-litigated every year or whenever a new delegate opens the file. Repeated full assessments consume public money, participant funds and clinical capacity. They also impose foreseeable psychological harm while adding little or no decision value where permanence is already established.

A standardised snapshot may understate complex disability. Fluctuating, episodic, psychosocial, cognitive, communication, sensory and multiple disabilities do not always present consistently in a single interview or tool. A person may mask, have a good day, lack insight, be unable to communicate risk, or perform a task only because intensive support is present.

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A reporting error can determine whether an ordinary day is possible. Participants rely on practitioners to translate complex lives into short reports written for statutory decision-making. If the report is poorly drafted, the participant is often expected to repair the professional’s work and carry the funding consequence in the meantime. Delegates should not hunt for isolated errors while ignoring the report as a whole. They should identify the concern, seek clarification, allow correction and decide on the complete evidence.

More disability-specific work will be shifted to families. The Bill strengthens assumptions about parental and informal support, including a presumption concerning substantial parental care and support. Without a strict distinction between ordinary age related parenting and disability-specific support, parents may be expected to provide supervision, personal care, transport, emotional support and behavioural support at levels that are unsafe or impossible to sustain.

Social and community participation may become a budget target rather than an individual right. Social participation funding pays for disability-related assistance needed to access ordinary community life; it does not pay the ordinary cost of hobbies. A category-wide reduction can mean isolation, loss of relationships, reduced safeguarding, loss of skill, less respite from continuous care and greater dependence on family.

Families will carry the risk of rigid plan-change rules. A serious change may be urgent but not neatly “significant and ongoing”, or may arise from provider collapse, housing instability, family violence, bereavement, school exclusion, a failed transition or underfunding in the original plan. A narrow reassessment test and a 90-day Agency decision period can leave families managing risk without resources.

Plan expiry and loss of carryover can punish people for market failure. Underspend can reflect hospitalisation, inability to recruit workers, delayed invoices, unavailable services, thin markets, delayed assistive technology, staged home modifications or the need to reserve flexible funding for episodic disability. It does not necessarily mean the support was unnecessary.

An approved safeguard can remain trapped in serial process. Our family has experienced home modifications being approved, followed by continuing demands for reports and quotes even after a Positive Behaviour Support Plan strengthened the safeguarding evidence. Legitimate technical requirements should be identified once, in writing, and managed through a single case pathway. Repeated demands without a final implementation decision waste money while known risk remains in the home.

The permanence test can create pressure to undergo treatment. The July amendment clarifies that treatment must be regularly undertaken in Australia and publicly funded, and excludes restrictive practices. [3] It still leaves difficult questions about waitlists, geographic availability, clinical risk, side effects, cultural acceptability, consent, treatment fatigue and whether treatment would materially improve functional impairment.

Other service systems can become an eligibility trap. A person may be theoretically eligible for compensation, health, education or other services but unable to obtain timely or adequate support. If theoretical responsibility is treated as actual availability, the person can be left in a gap while governments dispute who should pay.

Administrative failure can become debt or loss of support. Three-year record retention, debt consequences when records are absent, a 90-day claim deadline and suspension after failed contact can disproportionately affect people with cognitive disability, communication disability, psychosocial disability, unstable housing, family violence, hospitalisation, limited digital access or unreliable nominees and providers.

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Trusted providers may disappear. Expanded registration and commissioned panels may improve safety in some settings, but poorly designed compliance and pricing can drive out small, specialist, culturally safe and regional providers. Choice on paper is meaningless if no viable provider remains.

Fiscal discipline must apply to provider revenue, not only participant entitlement. Participants are not the only place Parliament can look for accountability. Providers, including charities, religious bodies and not-for-profits, may conduct commercial activity, and some organisations can access income-tax and other concessions. Qualifying NDIS supplies may also be GST-free. [16]-[18] If an organisation earns fee-for-service revenue from participant plans, that public money should be fully traceable and its commercial income should face equivalent effective tax and transparency rules regardless of legal form. Savings should not be extracted from a disabled person’s supports while provider-side concessions remain beyond scrutiny.

Automated error can scale rapidly. The Department states that automation will be used for high-volume administrative actions and that human oversight and review rights will remain. [4] Even an “administrative” action can interrupt payment, create debt, reject a claim or trigger loss of service. Publication seven days before an arrangement begins does not by itself make the logic fair or understandable. ROBO DEBT.

Costs will move, not vanish. When individualised support is reduced before a genuine alternative exists, families commonly absorb extra hours, leave paid employment, lose income and superannuation, postpone their own health care, reduce attention to siblings and rely more heavily on emergency systems. Carers Australia has warned that the Bill may shift costs and responsibilities to family and friend carers and accelerate burnout. [10]

Hospitals cannot become the default disability system. Australia’s hospitals are already carrying extraordinary demand. In 2024-25 there were 9.1 million public hospital emergency-department presentations, only 53 per cent were completed within four hours, and for patients subsequently admitted the figure was only 30 per cent. The time within which 90 per cent of admitted patients completed emergency care was almost 19 hours. [15] Hospitals provide healthcare; they do not replace daily personal assistance, supervision, communication support, behaviour support, supported decision-making, transport, community access or stable home and living support. Removing people from the NDIS and expecting hospitals or health departments to pick it up is, frankly, insane. The predictable results are preventable crisis presentations, delayed discharge, carer collapse, mental-health deterioration, institutionalisation and higher whole-of-government cost.

Detailed submission on the Bill

This section follows the Bill’s main architecture. References to Schedule and Part are based on the Government fact sheets and public Bill materials. [2]

The Bill gives legal force before the critical design is known The Department states that consultation on the new planning process, functional capacity eligibility assessment and related market reforms will begin in the second half of 2026. [4] In other words, Parliament is being asked to enact enabling powers before the community has seen, tested or influenced many of the operational details that will determine access and budgets. This sequencing is backwards for a rights-affecting scheme. The legality and practical fairness of an assessment regime depend on the definition being measured, the tool, thresholds, evidence rules, assessor qualifications, accommodations, quality assurance, algorithmic components, reasons and review mechanisms. Parliament cannot properly assess proportionality when those components remain unsettled.

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Minimum amendment: commencement should be conditional on publication of all instruments and materials, independent validation, accessible consultation capable of changing the design, pilot evaluation, parliamentary disallowance and a statutory no-detriment transition. The Bill should not permit substantive eligibility or budget criteria to be altered by non-legislative documents incorporated “as updated from time to time”.

Schedule 1, Part 1 - functional capacity and access A consistent approach to functional capacity can be legitimate if it improves transparency and reduces arbitrary differences. The problem is not the use of functional evidence. The problem is allowing an unknown standardised process to become the gateway to the Scheme while a policy objective is to reduce participant numbers substantially. Functional capacity is relational. It reflects the interaction between impairment, environment, technology, support, communication, relationships and risk. The Parliamentary Library notes this biosocial foundation and the importance of environmental factors. [5] Assessment must therefore distinguish what a person can do independently, safely, reliably, repeatedly and within a reasonable time from what they can do only through unpaid or funded support. A tool must not treat the presence of support as evidence of lesser need. It must not average away episodic or fluctuating impairment. It must accommodate people who cannot self-report reliably, use non-standard communication, experience trauma, mask disability, have multiple impairments, or live in inaccessible environments. It must include the participant’s own account, the account of trusted supporters where authorised, and relevant treating evidence. For current participants, loss of access should require more than one score. It should require a reasoned human decision, two appropriately qualified assessments where exit is proposed, consideration of longitudinal evidence and support history, written reasons, automatic internal reconsideration, funded advocacy and continuation of supports until external merits review is complete. For clearly lifelong impairments, access status should be stable; support needs can be reviewed without repeatedly reopening whether the disability exists.

Schedule 1, Part 2 - limits on unscheduled plan reassessment The Bill confines requests to participants, nominees or guardians and narrows the circumstances in which an unscheduled reassessment can occur. The Department states that the NDIA may take up to 90 days to decide whether to vary or reassess a plan, although crisis, emergency or fraud may be addressed through variation. [4] This structure is too rigid. Disability-related risk does not always fit a stable category. A provider can fail overnight. A parent can be hospitalised. A person can lose housing, be excluded from school, experience violence, have a communication breakdown, lose a key worker or receive a plan that was inadequate from the beginning. Some changes are urgent even if their duration cannot yet be proved. The Act should permit any person authorised by the participant, an advocate with consent, and specified safeguarding bodies to notify the Agency of a material change. It should require a rapid triage decision, an interim safety variation within 48 hours where serious harm is reasonably possible, and a final decision within 21 days unless the participant agrees otherwise. Refusal should be reviewable and reasons must identify the evidence and statutory test applied.

Schedule 1, Part 3 - the direct link between impairment and support The Bill states that a support is funded only where the need arises directly from an impairment for which the person met access. [2] This risks fragmenting people with multiple or interacting impairments and excluding supports needed because of secondary effects, environmental barriers or the interaction between disability and another condition. A disability system should assess function and support need in the real world. For example, communication impairment may interact with anxiety, trauma or cognitive disability; mobility impairment may create health and access consequences; sensory disability may affect behaviour and community safety. Artificially assigning each need to a single impairment encourages jurisdictional disputes and repeated evidence rather than practical support.

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The statutory test should be whether the need arises from, is materially related to, or results from the interaction or secondary effects of an access impairment. The Agency should not refuse an indivisible support merely because more than one impairment or system contributes to the need.

Schedule 1, Part 4 - Ministerial support determinations The Bill enables the Minister to reduce funding for specified groups of supports. The July amendment clarifies that a determination identifies the plans or groups to which it applies and is directed to social, community and civic participation and/or capacity-building daily activities, with power to exclude specified supports. [3] The central power remains a power to reduce funding by category rather than by individual assessment. This is a blunt rationing mechanism. A category label does not reveal the function of the support for a particular person. Community access may be the means by which a person maintains communication, prevents restrictive practices, develops daily living capacity, obtains safeguarding through contact with others, sustains employment or prevents family breakdown. Capacity-building support may reduce future support need. Cohort-wide reductions can therefore be counterproductive even on a financial measure. The power should be deleted. If retained, the Act must require public evidence of the problem being addressed, consideration of less restrictive alternatives, co-design, a disability and family impact assessment, a statement of compatibility addressing individual and cumulative impacts, parliamentary disallowance, independent review, a sunset clause, preservation of individually assessed minimum need, and exceptions for safety, communication, behaviour support, employment, disability-related health, rural or thin markets and carer sustainability. Every affected participant must receive individual notice, reasons explaining how the determination changes their plan, an opportunity to provide evidence, access to a hardship or safety exemption and merits review. A legislative instrument should not be able to extinguish the practical value of an individual plan without an individual remedy.

Parental responsibility and informal support The introduced Bill strengthens the presumption that parents are responsible for substantial care and support, including supervision, personal care, transport, emotional support and behavioural support, together with other age-ordinary daily living assistance. The distinction between ordinary parenting and disability-specific support is therefore critical. Parents are responsible for parenting; they are not an unlimited disability workforce. A non-disabled child of a similar age may require a parent to be present, but may not require continuous line-of-sight supervision, two-person personal care, specialised behaviour support, manual handling, complex communication assistance, sleep disruption or constant risk monitoring. The relevant comparison must include intensity, skill, duration, frequency, risk and the cumulative effect on the whole family. The Bill should not permit refusal where the primary purpose is characterised as reducing parental burden. The purpose of support is often to meet the child’s disability-related need; a reduction in unsustainable parental burden is a necessary consequence and a safeguard for the child. The decision must consider material risk of harm broadly, including burnout, family violence, relinquishment risk, loss of employment, sibling impact and the long-term sustainability of the care arrangement. Any parental responsibility provision should expressly state that parents are not expected to provide disability-specific care beyond what is reasonable and sustainable in all the circumstances; that family support is voluntary and cannot be assumed; and that the participant’s rights and best interests are primary. Families should be included in assessment with the participant’s consent, but should not be compelled to disclose private health or financial information as the price of the participant receiving support.

Schedule 1, Part 5 - plan end dates, renewal and no carryover A clear plan end date can improve administration only if continuity is absolute. The Bill provides for an immediate renewed plan but does not carry unspent funds forward. [2] The law must protect participants from a gap created by Agency delay, system failure, delayed invoicing or a dispute about the renewed budget.

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Unspent funds are not automatically excess funds. Disability can be episodic. A person may need to preserve flexible support for a foreseeable high-risk period. Equipment, home modifications and specialist services may be delayed. Regional participants may be unable to spend because the market does not exist. A participant should not be penalised for prudent use, hospitalisation, service cancellation or provider scarcity. The Act should continue the existing plan until a lawful replacement is in effect and accessible. It should preserve existing service agreements and committed expenditure. Carryover should be available for episodic supports, capital items, delayed services, market failure and circumstances outside the participant’s control. The Agency should have to explain any non-carryover and provide a reviewable decision.

Schedule 1, Part 6 - reasonable and necessary support, sustainability and equity The Bill requires the Agency to consider scheme sustainability and equity across participants, including people with similar needs and circumstances, when determining reasonable and necessary supports. [2] Consistency is important, but the concept can become a ceiling if “similar” participants are grouped too broadly or if historical underfunding is reproduced as the benchmark. The NDIS Act already requires regard to financial sustainability while also requiring individualised plans, reasonable and necessary support, choice, control, community inclusion and lifetime certainty. [6] The Bill should not convert sustainability from a scheme-level stewardship obligation into an overriding reason to deny an otherwise necessary support to an individual. Equity should mean equal respect and support responsive to actual circumstances, not identical funding. The Act should state that a person cannot be denied support solely because another participant received less, and that comparable cases do not displace evidence of individual need, risk, goals, environment, communication or available informal support. The burden of fiscal restraint must not be placed selectively on people least able to absorb it.

Schedule 1, Part 7 - suspension and revocation after failed contact The July amendment requires direct contact with the participant, nominee or authorised person, at least five attempts through the preferred means of contact, and a period of three to four months between first and last attempt. Attempts do not count while the person is in hospital, an institution or experiencing homelessness. [3] These are useful safeguards but remain incomplete. Failure to respond may be evidence of vulnerability: cognitive or communication disability, family violence, coercive control, trauma, mental health crisis, exploitation, unsafe housing, hospitalisation not known to the Agency, death of a nominee, digital exclusion, changed contact details or loss of informal support. Suspending funds can remove the very workers who might locate and safeguard the person. Revoking participant status after 90 days compounds the risk. The Agency should be required to undertake a documented safeguarding assessment before suspension, contact all authorised and trusted contacts, use accessible and culturally appropriate methods, check known service providers where lawful, offer independent advocacy and consider continuation of essential supports. Revocation should require a formal human decision, senior approval, reasons and merits review, and should not take effect while review is available. Reinstatement should be automatic and should not require a new access application.

Schedule 1, Part 8 - permanence and treatment The Bill tightens permanence by requiring that appropriate treatment has been undertaken, no likely treatment would materially improve the impairment, and the impairment is likely to be lifelong. [2] The July amendment clarifies publicly funded treatment regularly undertaken in Australia and excludes restrictive practices. [3] The remaining test must be applied consistently with informed consent and bodily autonomy. A treatment may be clinically available but unsafe for the individual, contraindicated, intolerable, culturally unacceptable, geographically inaccessible, subject to years of waiting, unaffordable in practice, or unlikely to improve functional impairment even if it changes symptoms. A person must not be forced to choose between treatment they do not consent to and disability support.

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The Act should require the Agency to prove that the proposed treatment is evidence-based, clinically appropriate to the person, safe, realistically accessible within a reasonable time, publicly funded in full, acceptable after supported decision-making, and likely to materially and durably improve functional capacity. Refusal of treatment should not itself justify refusal of access. Treating-practitioner evidence should be central and rare, progressive, degenerative, episodic and psychosocial conditions must be expressly accommodated.

Schedule 1, Part 9 - access to other service systems or compensation The Bill permits eligibility consequences where a person accesses or may be eligible for workers’ compensation, motor accident or other systems. [2] Coordination is reasonable; exclusion based on theoretical eligibility is not. Mainstream and compensation systems often have different purposes, waiting periods, exclusions, evidentiary tests and service limitations. Health services in particular are not funded or designed to provide ongoing daily disability support. A hospital bed cannot substitute for a support worker, stable housing, supported decision-making or community participation. A person may be legally eligible but practically unable to obtain an appropriate support. The NDIS should not withdraw or refuse support until the alternative is actually available, equivalent, accessible and safe. The Act should establish a no-wrong-door rule. The participant should receive continuous support while governments or insurers resolve liability. Where the proposed alternative is a hospital or health service, the Agency must identify the precise legal duty, funded service, waiting time, location and responsible decision-maker. The Commonwealth may recover appropriate costs from the responsible system, but the disabled person should not be left unsupported or required to litigate a boundary dispute to meet daily needs.

Schedule 2 - fraud, provider regulation, records, debt and claims I support stronger action against deliberate fraud, unsafe providers, coercion, conflicts of interest and organised exploitation. The integrity response must nevertheless distinguish participants from commercial actors who control billing, records and systems. Disability-related administrative difficulty is not fraud. The Bill requires providers and participants to retain payment records and can create a debt where a person received an NDIS payment but did not keep required records. It also reduces claims to 90 days. [2] These measures can produce disproportionate consequences where a participant was substantively entitled to the support but a provider, nominee, technology platform or disability-related barrier caused the documentation failure. Participant obligations should be simple, accessible and supported. There should be a broad reasonable excuse defence, a duty on the Agency to help reconstruct records, protection for good-faith reliance on registered providers or plan managers, proportionality, and no debt without proof that the person received or retained money to which they were not entitled. Civil penalties and investigative powers used against participants should require a documented risk assessment, senior authorisation and access to legal assistance. A 90-day claims deadline is too short for a disability scheme. Late claims may result from hospitalisation, bereavement, family violence, provider delay, invoice correction, nominee failure, system outage or executive-function and communication disability. A 12-month standard period with mandatory extensions is more proportionate and does not prevent the Agency from imposing shorter provider invoicing standards by contract where appropriate.

Provider registration and plan management panels Risk-proportionate registration can strengthen safety, especially for intimate personal care, closed settings and behaviour support. It must not be implemented as a one-size-fits-all barrier that excludes trusted sole traders, peer workers, culturally specific providers, innovative supports or providers in thin markets. Compliance costs, audit requirements and Ministerial pricing interact. If the price does not fund the cost of registration and a viable workforce, providers will leave or refuse complex participants. Participants will then appear to have underspent, lose continuity and rely more heavily on family. The Bill should require

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transition grants, simplified pathways, portable worker screening, recognition of proportionate quality systems and active market stewardship. The Government amendments clarify conflict arrangements for plan managers. [3] A commissioned panel must still preserve participant choice, regional coverage, cultural safety, conflict transparency and continuity. A participant should not be compelled to change a competent plan manager merely because a procurement panel changes.

Schedule 3, Part 1 - Ministerial pricing The Bill makes the Minister the decision-maker on NDIS pricing, informed by NDIA advice. The July amendment requires a summary of that advice to be tabled within five days after a pricing determination. [3] Post-decision publication is not equivalent to independent price setting or meaningful prior scrutiny. Price controls can protect public funds, but underpricing is rationing by another name. It can reduce worker quality, training, supervision, continuity and availability, particularly for complex support, travel, overnight work, regional areas and small specialist markets. Families then carry the service failure. Pricing governance should be independent, evidence-based and transparent. The methodology, cost assumptions, stakeholder evidence and distributional impact should be published before decision. There should be consultation, reasons for departure from independent advice, explicit thin-market loadings, regular indexation and a mechanism for urgent correction where providers cannot deliver safely at the set price.

Schedule 3, Part 2 - automated administrative action The Bill permits automation of specified administrative actions. The Department states that human oversight, review rights and standard operating procedure instruments will apply, and the July amendment requires publication of certain arrangements at least seven days before commencement. [3][4] The label “administrative” should not determine risk. Claims, payments, records, debt, plan status and provider compliance can all interrupt essential support. Automated systems can reproduce errors consistently and at scale, use inaccurate data, apply a rule outside its intended context or create an evidentiary burden on the participant to prove the machine wrong. The Act should prohibit automation of any decision or trigger that can adversely affect access, budget, support continuity, plan suspension, participant status, debt, penalty or a disputed claim. Low-risk automation should require a named accountable officer, published rules and data fields, impact assessment, privacy and security controls, testing across disability groups, audit logs, error reporting and independent oversight. Every affected notice should state that automation was used, identify the data and rule relied on in understandable terms, provide the full reasons and evidence, and offer a rapid, no-cost human reconsideration that pauses adverse effect. A CEO power to replace an incorrect action after the event is not an adequate remedy where a person has already lost a worker, housing or safety.

Schedule 4 - new framework planning and delegated law Schedule 4 enables budget method rules, support needs assessments, rules about what assessors may consider, transition notices, incorporation of NDIA documents that can be updated over time, and broader value-for-money assessment. [2] These matters define practical entitlement and should not be hidden in operational material. New planning may improve consistency if it is transparent and genuinely individualised. It will not be fair if a standard assessment produces a budget through unpublished weighting, if the participant cannot correct the record, if the assessor cannot consider treating evidence, or if value for money is reduced to the cheapest quotation without regard to suitability, durability, safety, cultural needs and whole-of-life cost. The Act should contain the essential budget principles. Rules should be disallowable. Dynamic incorporation of changeable Agency documents should be prohibited for any matter affecting eligibility, evidence, support categories or budget calculation. Participants should receive the assessment record,

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scoring, assumptions, budget calculation and reasons in accessible form, with a right to correct factual errors and obtain merits review of the resulting plan.

Foundational supports, transition and the 2029 review The Government presents foundational supports and more inclusive mainstream systems as part of the replacement ecosystem. The Parliamentary Library notes substantial committed funding but also identifies that particular programs do not replace individual adult social participation support one for one. [5] The Department says consultation on key design matters will continue after the Bill. [4] A future program is not a present service. A group activity is not necessarily a substitute for one-to-one, communication-aware, trauma-informed or behaviour-support-informed assistance. A service in a capital city is not available to a remote participant. A website or referral is not support. The law must test actual availability and adequacy, not policy intention. The 2029 review added by the House amendments is welcome but too late as the sole safeguard. [3] Access and plan changes begin earlier. Harm such as loss of housing, family breakdown, workforce exit or institutionalisation may be irreversible. Parliament needs quarterly data and independent monitoring from commencement, reviews at 12 and 24 months, a participant-led oversight body and statutory pause or sunset mechanisms.

Review rights, reasons and access to justice The practical value of a right depends on whether a person understands the decision, can obtain the evidence, can access representation and remains supported while the review occurs. A successful appeal months later does not repair avoidable crisis, homelessness, loss of a trusted workforce or family breakdown. Every access, budget, support determination, suspension, debt and automated action should produce complete and accessible reasons identifying the legal test, evidence, assessment result, calculation and review route. Internal review should be independent of the original decision. Essential supports should continue pending merits review unless a specific and immediate safety reason requires otherwise. Additional funding is required for independent disability advocacy, supported decision-making and legal assistance. The Law Council has raised similar concerns about discriminatory barriers in permanence, unequal statutory timeframes, cohort reductions, automation, penalties, suspension, review rights and legal assistance. [8] Australia’s Disability Representative Organisations have also called for the Bill not to proceed in its current form pending evidence, stronger safeguards, operational alternative supports and genuine consultation. [9]

Cost-shifting to hospitals and health departments is unsafe and fiscally false The Bill must be assessed against the actual capacity of the systems expected to absorb need. AIHW recorded 9.1 million public hospital emergency presentations in 2024-25. Only 53 per cent of presentations were completed within four hours; among people admitted to the same hospital, only 30 per cent were completed within four hours, and the 90th percentile duration was 18 hours and 57 minutes. [15] These figures do not prove that every NDIS reduction will cause a hospital presentation, but they demonstrate that the health system has no spare basis on which Parliament can casually transfer disability-support demand. Daily disability support and healthcare are different public functions. When personal care, supervision, behaviour support, communication assistance, supported decision-making, home and living support or community access is withdrawn, the unmet need can reappear as injury, preventable deterioration, mental-health crisis, family breakdown, emergency presentation, delayed discharge or institutional placement. A nominal NDIS saving can therefore produce a larger state or territory health cost and a worse outcome. Before any cohort reduction, access reassessment or support determination commences, the Commonwealth should publish state-by-state whole-of-government modelling and binding intergovernmental implementation agreements. The NDIS must continue support unless and until the

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alternative service is legally responsible, funded, staffed, accessible, clinically and culturally appropriate, and actually available. Otherwise the reform is not a saving; it is a concealed transfer of cost and risk.

Tax neutrality and accountability for NDIS-funded provider income The Bill subjects participant entitlement to intense fiscal scrutiny but does not use the same lens on the tax treatment of organisations earning from participant plans. The ATO states that qualifying supplies to an NDIS participant can be GST-free, that certain organisations may be income-tax exempt, and that endorsed religious institutions can access income-tax exemption. The ACNC confirms that charities may undertake commercial activities where those activities advance their charitable purposes. [16]-[18] Federal parliamentarians themselves receive an electorate allowance as part of their remuneration. The determination in force from 1 July 2025 provides every senator and member of the House of Representatives with a base allowance of $39,700 per year. A House member receives $47,200 where the electorate is between 2,000 and 4,999 square kilometres and $57,100 where it is 5,000 square kilometres or more. The allowance is paid fortnightly with salary. The ATO’s ruling requires members generally to include parliamentary allowances as assessable income and permits deductions only for eligible expenses actually incurred in carrying out parliamentary duties. The legally accurate point is therefore not merely that an ‘unspent balance’ is taxed: the allowance is assessable income from the outset, and any amount not offset by allowable deductions remains taxable, whether unspent or spent for a non-deductible purpose. If Parliament accepts this form of tax accountability for allowances paid to its own members, it should not dismiss equivalent transparency and tax-neutrality principles for organisations earning commercial revenue from NDIS participant plans. [26] Charitable status should not obscure the character of a fee-for-service transaction funded by a participant’s public plan. Donations and genuinely philanthropic activity are one thing; commercial revenue earned by selling NDIS services is another. I support a clear rule that all NDIS-derived provider income, margins and related-party payments are separately identified in accounts and reported to the NDIA, ATO and relevant regulator. Equivalent services should face equivalent effective taxation regardless of whether the provider is a company, charity, church, public benevolent institution or other not-for-profit. Parliament should commission urgent tax and competition modelling and either remove status-based exemptions for commercial NDIS income or impose an equivalent NDIS public-money levy. The design must prevent avoidance through related entities and must publish how much revenue is collected and reinvested in the Scheme. It must not tax participants, reduce plan budgets, reduce support hours or make essential services unavailable. The principle is simple: fiscal accountability should begin with every organisation taking public money from the Scheme, not with disabled people losing essential support.

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Repeated evidence, report quality and the right to a fair evidentiary process The NDIA’s public guidance requires evidence from appropriately qualified professionals and emphasises recent information for access and plan decisions. [19] Current evidence may be necessary where function, risk, circumstances or a proposed support has materially changed. That does not justify repeatedly commissioning broad assessments to re-establish a permanent impairment and lifelong functional reality already accepted by the Scheme. In my family’s experience, assessments and reports have been required repeatedly, often on an approximately twelve-month cycle. The public cost is multiplied: participant funds or private family money pay the practitioner; clinical capacity is diverted from treatment and support; the family spends hours in assessment; and the practitioner spends many more hours drafting. When a delegate then fails to engage with the central findings, the system has paid to create evidence it does not meaningfully use. That is the opposite of value for money. The human cost is equally serious. To answer comprehensively, a parent must repeatedly describe every limitation, risk and dependence and confront the permanent prognosis again. For my family, that means articulating that my children will never be independent without substantial support and will always need assistance across every domain. Repetition is not neutral administration; it can be re-traumatising and can damage trust, family wellbeing and willingness to engage. The Agency’s own Participant Service Charter promises transparent, responsive and respectful service, recognition that participants are experts in their own lives, understandable decisions and trained staff. Its reasonable and necessary guidance says planners assess the evidence given and explain their decisions. [20] NDIA co-design material has also recorded that participants want to avoid repeating their stories and that planners may arrive unprepared or unaware of disability history. [23] The legislation and operating model should convert those commitments into enforceable practice. A delegate should be required to identify each material report considered, the central findings accepted, any finding rejected and the evidence or statutory reason for rejection. The delegate should not extract one imperfect sentence and disregard the report’s overall clinical opinion. Where terminology is unclear, data is missing or conclusions appear inconsistent, the first response should be a targeted request to the author for clarification, copied to the participant, rather than an adverse inference. Practitioner error requires a system response. The participant did not control the report writer’s competence or drafting. The Agency should provide a no-cost correction period, help formulate clarification questions, preserve existing support during remediation and, with consent, refer serious quality concerns to the NDIS Quality and Safeguards Commission, Ahpra or the appropriate professional or consumer complaints body. The participant should not have to finance and prosecute two disputes - one with the practitioner and one with the Agency - merely to obtain an accurate decision. A statutory evidence passport should record accepted permanent impairments, longitudinal functional findings, communication and assessment adjustments, safeguarding risks and reports already supplied. A new request should state the specific decision issue, explain why existing evidence is insufficient, identify the minimum information required and confirm who will pay. Where the Agency requires an updated assessment because of its own delay, changed policy, expired quote or changed template, the Agency should fund it outside the participant’s support budget.

Home modifications, behaviour-support evidence and safeguarding delay NDIA guidance recognises that home modifications can address safety, access, daily tasks and carers’ needs. It also sets out assessment, design and quotation requirements, including additional material for complex works. [21] Proper technical and building scrutiny is necessary. It should, however, be predictable, proportionate and coordinated. It should not become an indefinite sequence in which each new document creates another request and no person owns the final safeguarding outcome. The NDIA approved home modifications for my family before a Positive Behaviour Support Plan was available. We now have a plan that provides further evidence of safeguarding needs, and the Agency is clearly aware of the risk. Yet the family has been required to obtain or revisit further reports, quotes and supporting material. Stronger evidence of risk should move an approved safeguard toward implementation; it should not send the participant back to the beginning.

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The Act or rules should require a single accountable home-modification pathway. Within a fixed period, the Agency should provide one consolidated written evidence and procurement schedule, identify what has already been accepted, explain any remaining legal or technical requirement, nominate a decision maker and project contact, and set final decision and implementation dates. It should not request a new quote merely because its own delay caused an earlier quote to expire without funding the replacement. Where new behaviour-support evidence changes the required design, the Agency should convene the participant, behaviour practitioner, occupational therapist, building professional and relevant support providers once, resolve the interface and issue a reasoned variation. Interim environmental or staffing safeguards must be funded until the modification is complete. An administrative process that keeps spending on reports while leaving the known hazard unchanged is not fiscally responsible and is not safeguarding.

COAG-style national accountability and no-wrong-door governance COAG ceased in 2020 under the Liberal government. Its intergovernmental architecture was replaced by National Cabinet arrangements. A Disability Reform Ministerial Council currently brings Commonwealth, state and territory disability ministers together and reports to National Cabinet. [22] I recognise that a national forum therefore exists. My concern is whether families can see clear responsibility, enforceable commitments, system capacity and timely resolution when the NDIS, health, education, housing and other systems each point elsewhere. In my view, Australia was better served when COAG provided a recognisable public mechanism through which national responsibilities could be negotiated and governments could be held collectively accountable. I ask for COAG back in substance: not necessarily the old name or every former procedure, but a visible forum with authority across portfolios, published agendas and communiques, transparent agreements, implementation data and direct accountability for unresolved disability-system interfaces. The existing Disability Reform Ministerial Council should be strengthened and cross-portfolio disputes should be escalated to First Ministers where necessary. People with disability, family representatives and independent experts should have a formal role. Governments should publish, by jurisdiction, which system is responsible for each support interface, funded service capacity, waiting times, geographic coverage, transition arrangements and what happens when the nominated service is unavailable. A binding no-wrong-door rule should require the system currently supporting the person to maintain continuity until the receiving system has accepted responsibility and an adequate service is actually operating. Governments can reconcile funding between themselves afterward. A disabled person and family should never be the enforcement mechanism for federalism.

Statutory principles

The NDIS Act is not merely an expenditure statute. Its objects include giving effect to Australia’s obligations under the Convention on the Rights of Persons with Disabilities, supporting independence and social and economic participation, providing reasonable and necessary supports, enabling choice and control and promoting community inclusion. Its principles include lifetime certainty, dignity, participation, co-design, support in dealings with the Agency, respect for family relationships and individualised planning. [6] The Bill engages, among other rights, equality and non-discrimination; equal recognition and supported decision-making; freedom from abuse, neglect and exploitation; independent living and inclusion in the community; personal mobility; family life; health and habilitation; education; work; social protection; participation in cultural and community life; and the right of people with disability and their representative organisations to be closely consulted and actively involved in disability law and policy. [7] Not every limitation on a right is automatically unlawful. Government may pursue legitimate aims such as sustainability, safety and integrity. However, restrictions should be clearly prescribed by law, supported by evidence, non-discriminatory, necessary, proportionate, individually reviewable and the least rights restrictive reasonably available means. Broad delegated powers, unknown assessment criteria and category-wide reductions make that demonstration difficult.

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Equality requires substantive, not identical, treatment People with disability have different support needs. Treating everyone identically can deepen inequality. A standardised tool or comparison cohort must not erase communication differences, environmental barriers, fluctuating disability, cultural context, trauma, rurality, gender, age or the availability and sustainability of informal support. Equity cannot mean reducing a person to the amount given to an administratively similar group.

Independent living requires practical support and choice The right to live in and participate in the community is undermined when individual support is replaced by an inaccessible or unsuitable general service, when social participation is cut by category, when provider choice collapses or when family members are required to substitute for paid support. Community inclusion is not achieved simply by placing people in group activities. It requires support responsive to individual communication, safety, relationships and goals.

Family life is not a licence for cost transfer Families are entitled to relationships that are more than continuous unpaid service delivery. Excessive reliance on parents, partners or siblings can undermine the disabled person’s autonomy, expose both parties to risk, force carers from employment and place children and siblings under pressure. The State should support family relationships, not use them as a reason to withdraw disability-specific assistance.

Bodily autonomy must govern treatment A permanence test linked to treatment must respect informed consent and the person’s physical and mental integrity. Access to disability support cannot be conditioned on accepting treatment that is unsafe, unacceptable, inaccessible or unlikely to improve functional impairment. Supported decision-making and treating evidence are essential safeguards.

Consultation must occur before the essential policy is fixed Consultation after enabling legislation is enacted is weaker than consultation capable of changing whether and how the power exists. The scale of this Bill, its cumulative interaction with prior NDIS amendments and the Government’s participant and expenditure objectives require a process led by people with disability, with accessible information, adequate time, support for participation and public explanation of how views changed the proposal.

Potentially retrogressive impact requires the strongest justification Measures that reduce access to social protection or community support may be retrogressive in practical effect even if described as administrative reform. The Government should identify each affected cohort, quantify likely exits and funding reductions, publish alternatives, evaluate discrimination and demonstrate why less harmful integrity and market measures cannot achieve the objective. Parliament should not accept fiscal targets as a substitute for rights analysis.

A fair go requires shared national responsibility The NDIS reflects an Australian social compact: the economic and personal consequences of lifelong disability should not fall solely on the person and family who happen to experience it. That compact is consistent with equality, dignity, family life and independent living. Replacing national responsibility with fragmented reliance on family, local services, hospitals, charity or litigation would undermine both the statutory objects and Australia’s commitment to a fair go.

Natural justice must govern evidence, reports and implementation Natural justice or procedural fairness is not an optional courtesy. For decisions that affect safety, daily assistance and community life, the participant should know the adverse issue, know the material being relied on, have a real opportunity to answer it, receive an impartial human decision and obtain reasons that engage with the evidence. The Bill should expressly preserve those minimum incidents, including before a report defect, assessment score or missing document is used to reduce or refuse support.

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The process should also be practically fair. A right to respond is hollow if the person must pay thousands of dollars for another report, cannot obtain an appointment within the deadline, loses support while the matter is corrected or is expected to litigate practitioner quality alone. Fair process requires funded assistance, reasonable time, accessible communication, continuity and a duty on the Agency to clarify rather than ambush. Natural justice should be ordinary governance, not an amazing exception available only after a family has fought for it.

A safer and more credible path to sustainability

The choice is not between the Bill and an uncontrolled Scheme. A sustainable NDIS can be pursued through measures that protect participants and focus first on leakage, market design and administrative quality.

Separate integrity from entitlement. Target organised fraud, provider collusion, false claims, conflicts of interest, price manipulation, coercion and unsafe practice through specialist capability, data matching with due process, payment controls, provider audits and criminal enforcement. Do not presume that reducing participant support is an integrity measure.

Measure total public cost. A reduction in NDIS expenditure can increase hospital, mental health, housing, education, justice, child protection and income-support costs and reduce tax revenue when carers leave work. A reform that saves Commonwealth NDIS expenditure while increasing state hospital costs or destroying carer employment is not a saving. Government should publish whole-of-government modelling, not only the NDIS ledger.

Use life-cycle insurance logic. Adequate early and preventive support can reduce crisis, injury, family breakdown, restrictive practice, institutional care and long-term dependence. Value for money should include durability, capability, safety and avoided downstream cost.

Build viable markets and public options. Set realistic prices, invest in training and supervision, support regional and specialist providers, improve worker conditions, and create direct public or not-for-profit commissioned capacity where markets cannot reliably provide essential services.

Improve decision quality before restricting review. Accurate first decisions, complete reasons, trained delegates, specialist teams, participant evidence and early resolution reduce review cost and distress. Rigid reassessment barriers merely suppress correction of wrong plans.

Co-design, pilot and publish. Test assessment and planning methods with diverse disability cohorts, publish results and revise before national rollout. Independent evaluation and participant-led governance should be built into implementation, not added after harm occurs.

Protect continuity during change. Grandfather established access where impairment is clearly lifelong, maintain supports pending review, honour service commitments and use no-detriment transition funding. System reform should not make individual families carry implementation risk.

Establish permanence once and fund only targeted new evidence. Create a durable evidence passport for accepted lifelong impairment and longitudinal function. Require new reports only for a clearly identified material issue, use the least burdensome evidence capable of answering it, and make the Agency pay where it requests the assessment. Audit how much participant funding and family money is consumed by repetitive reports and publish the savings from ending duplication.

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Correct report problems without punishing the participant. Train delegates to interpret clinical and medico-legal reports, require report-by-report reasons, and establish a direct clarification and remediation process with practitioners. Preserve funding while genuine defects are corrected. Collect quality data and refer recurrent unsafe or incompetent reporting to the appropriate regulator instead of making individual families police the professional market.

Finish approved safeguards through one pathway. For home modifications and other complex safeguards, appoint one accountable case lead, issue one consolidated evidence schedule, coordinate all disciplines, prevent moving requirements and fund updates caused by Agency delay. Measure time from recognised need to functioning safeguard, not merely time to the next administrative step.

Make intergovernmental responsibility visible and enforceable. Strengthen the Disability Reform Ministerial Council with COAG-style transparency and First Ministers escalation. Publish interface responsibilities, funding, service capacity and unresolved gaps. Apply a binding no-wrong-door continuity rule so that governments, rather than participants, bear the risk of jurisdictional disagreement.

Keep the NDIS Australian and national. Australia should learn from overseas systems without copying their fragmentation. Retain a national entitlement, nationally consistent safeguards, portability, individualised funding and enforceable review rights. Foundational supports can complement this national core but must not replace it with local, school, health, insurance or charity-based gatekeeping.

Apply the same fiscal scrutiny to provider-side revenue. Separate charitable donations from commercial NDIS service fees, require NDIS-derived revenue and related-party payments to be reported as distinct classes, review status-based tax exemptions, and apply equivalent effective taxation or an NDIS public-money levy. Reinvest any revenue in participant supports, independent advocacy, fraud prevention, workforce quality and thin markets. Do not finance reform by cutting participants.

I respectfully request the Committee’s permission to speak to this submission and to give oral evidence at any further public hearing. I ask to be invited as a witness. Written submissions cannot fully convey the cumulative work performed by families, the way different provisions interact, or the consequences of uncertainty for people whose disability and support needs are lifelong. I would address the following matters:

• my children’s experience before the NDIS and why the Scheme’s national promise matters;

• ’s profound intellectual impairment, Level 3 pre-verbal/non-verbal autism and Phelan-McDermid syndrome, my son’s Cantú syndrome, and why rare genetic disability requires specialist evidence to be understood and applied;

• what adult-sized intimate personal care requires each day, and the reality of constantly triaging between two children whose needs do not pause;

• the loss of ordinary social participation, friendships and respite after years of continuous unpaid disability care;

• the constant pressure, burnout and fear created by having to fight repeatedly for lifelong needs;

• the financial, clinical and psychological cost of repeatedly re-proving permanent disability;

• how delegates demand clinical and medico-legal reports but may fail to understand, acknowledge or apply them;

• why participants should not carry the funding consequence of a practitioner’s badly written report;

• the home-modification process, the later Positive Behaviour Support Plan and the need to turn known safeguarding evidence into completed works;

• why my children are themselves the future generations named by the Bill, and why lawmakers should see a full day of disability support in practice;

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• the need for strengthened COAG-style Commonwealth-state accountability and enforceable no-wrong-door arrangements;

• why Australia should preserve its own national social-insurance model rather than reproduce fragmented overseas arrangements;

• the likely transfer of unmet disability need to already pressured hospitals and health departments;

• tax neutrality and transparency for charities, churches, not-for-profits and other providers receiving participant-plan revenue;

• the difference between ordinary family support and disability-specific care;

• why supported functioning must not be mistaken for unsupported capacity;

• the consequences of category-wide social and community support reductions;

• the risks created by plan rigidity, failed contact, records, debts and short claim periods;

• the importance of continuity while access or funding decisions are reviewed; and

• the safeguards required before functional assessment, automation and new framework planning commence. I can appear by video conference or phone. I consent to contact from the Committee Secretariat at or . Subject to my children’s informed consent, privacy, dignity and safety, I also invite Committee members or an authorised delegation to observe a day in our family’s life through a private visit or structured briefing. Bill Shorten did so, and around that period the practical need for our home modifications was recognised. Direct observation is not a substitute for evidence or law, but it can prevent abstract assumptions about parental responsibility, independence, vulnerability and reasonable and necessary support.

Please record this submission as an express request for permission to speak and to appear as a witness. If witness places are limited, I ask the Committee to prioritise direct evidence from participants and families affected by lifelong, significant and permanent disability, including people who require communication support and those outside Canberra.

My children were diagnosed before the NDIS. I know what came before it, and I do not want Australia to go backwards. I believed the NDIS would mean safety, quality of life and an end to permanent fighting. I do not seek sympathy or special treatment. I seek the fair go Australia says it gives. Families like mine do not oppose accountability. We live with the consequences when providers are unsafe, plans are wrong and public systems fail to coordinate. We want an NDIS that is financially responsible, evidence-based and protected from fraud. But the Scheme cannot be secured by making disabled people and families absorb uncertainty, unpaid labour and crisis. The Bill shifts too much substance into executive power, delegated instruments, future assessment design and automated administration. It allows support to be reduced across categories even where individual need remains. It narrows pathways for correction, increases administrative consequences and treats alternative systems and family care as available more readily than reality may justify. The July amendments add some safeguards but do not change the Bill’s basic direction. A 2029 review cannot prevent harm beginning in 2026, 2027 or 2028. Five contact attempts do not answer the safeguarding problem. Publishing automation arrangements seven days before use does not make adverse automation appropriate. Clarifying publicly funded treatment does not resolve consent and access. Identifying the support categories subject to reduction does not make a category-wide reduction individualised. I want my children to be safe and to have a quality of life. I want to be happy again, rather than constantly exhausted and afraid that the next administrative or legislative change will remove what they need. A country should not make a parent spend a lifetime fighting simply because their children were born disabled. My children are not separate from the future generations this Bill claims to protect. They are those future generations. They deserve to enter adulthood with greater certainty than the system gave them as

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children, not with a new statutory architecture that reopens permanence, narrows support and shifts the burden back to family. A system is not fiscally responsible when it repeatedly orders costly assessments to prove what is already permanent, overlooks the reports it demanded, searches them for defects, leaves participants to fight practitioners over poor drafting and then spends more money recommissioning evidence. Nor is it responsible to approve a home safeguard, receive stronger behaviour-support evidence and continue purchasing reports and quotes while the safeguard remains unfinished. I ask Parliament to apply natural justice before harm, not only after appeal. Read the evidence as a whole. Tell the participant what is missing. Help correct genuine errors. Give reasons. Maintain support. Complete known safeguards. And before deciding what a family can reasonably provide, spend a day seeing the work, vulnerability and responsibility that the words on a plan represent. Australia is the Lucky Country only if luck is not reserved for people who happen not to be disabled. Being fair dinkum means confronting the real costs rather than moving them off one budget line. Giving everyone a fair go means preserving a national system that shares the responsibility of lifelong disability, rather than returning it to families, hospitals and charity. I therefore ask the Committee to recommend that the Bill not be passed in its current form. At minimum, Parliament should entrench continuity, individualised entitlement, family sustainability, transparent assessment, informed consent, human decision-making, meaningful reasons, merits review, accessible advocacy, parliamentary control of substantive rules and operational replacement supports before any reduction occurs.

A sustainable NDIS should reduce waste, prevent exploitation, build capability and fund support that keeps people safe and included. It should not become sustainable only because families silently replace formal support or hospitals absorb preventable crises. Australia cannot claim to give everyone a fair go while disabled people and their families carry the full risk. Secure their rights, safety and continuity, and the Scheme will be more secure as a result.

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Appendix A - Clause-to-recommendation index

Bill provision or issue Requested safeguard

Schedule 1, Part 1 - functional capacity Recommendations 2-5; publish and validate tools, use whole-person assessment, protect current participants and continue supports pending review.

Schedule 1, Part 2 - unscheduled reassessment Recommendation 6; broaden triggers, allow safety notifications and impose rapid decision timeframes.

Schedule 1, Part 3 - direct link to access impairment Recommendation 7; use a material relationship and interaction test.

Schedule 1, Part 4 - support determinations Recommendation 8; delete the power or impose individual minimum need, exemptions, review, evidence, disallowance and sunset.

Parental responsibility and informal support Recommendation 9; distinguish ordinary parenting from disability specific care and assess family sustainability.

Schedule 1, Parts 5 and 6 - renewal, carryover and Recommendations 10-11; preserve individualised funding, seamless reasonable and necessary supports continuity and justified carryover.

Schedule 1, Part 7 - suspension and revocation Recommendation 12; safeguarding, advocacy, essential support continuation and automatic reinstatement.

Schedule 1, Part 8 - permanence Recommendation 13; consent, safety, realistic availability and no disadvantage for treatment refusal.

Schedule 1, Part 9 - other systems Recommendation 14; no-wrong-door continuity until an adequate alternative is actually available.

Schedule 2 - fraud and provider measures Recommendations 15-18; proportional records and debt rules, longer claims, risk-proportionate registration and plan-management choice.

Schedule 3 - pricing and automation Recommendations 19-20; independent transparent pricing and prohibition of automated adverse decisions.

Schedule 4 - new framework planning Recommendation 21; primary-law criteria, disallowable rules, no dynamic incorporation and full reasons.

Foundational supports and transition Recommendations 22-24; actual replacement supports, early monitoring, stop mechanisms and advocacy.

Family and equality impacts Recommendation 25; mandatory family and intersectional impact analysis.

Committee participation Recommendation 26; grant permission to speak and invite direct oral evidence with remote access and reasonable adjustments.

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Appendix A - Clause-to-recommendation index (continued)

Bill provision or issue Requested safeguard

Whole-of-government cost shifting and health- Recommendations 14 and 27; sections 4 and 5.19. Do not system capacity transfer daily disability need to hospitals or health departments; require funded, operational alternatives and whole-of-government modelling.

Tax treatment and public-money Recommendation 28; section 5.20. Trace every provider accountability for provider revenue payment, separate commercial NDIS income from donations, and apply equivalent effective taxation or a public-money levy regardless of entity form, without taxing participants.

Australian national social-insurance model Recommendation 29; sections 4, 6.7 and 7. Preserve national entitlement and reject fragmented state-, school-, health-, insurance- or charity-based gatekeeping.

Repeated evidence, report costs and Recommendations 30-31; sections 3, 4, 5.21 and 6.8. Establish practitioner error permanence once, fund any necessary new evidence, require delegates to engage with material reports, provide an opportunity to cure defects and create a no-cost report-quality pathway.

Home modifications and safeguarding Recommendation 32; sections 3, 4 and 5.22. Use one evidence accountable pathway, recognise relevant behaviour-support evidence, prevent serial report and quote demands, fund duplication caused by Agency delay and maintain interim safeguards.

Intergovernmental governance and COAG-style Recommendation 33; sections 5.23 and 7. Strengthen the accountability current national disability forum, publish responsibilities and capacity, create binding no-wrong-door arrangements and resolve jurisdictional disputes without interrupting support.

Sources were accessed on 10 July 2026. Government fact sheets summarise the Bill and House amendments; the Bill text and any later parliamentary amendments remain authoritative.

[1] Parliament of Australia, Senate Community Affairs Legislation Committee, Inquiry: National Disability

Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 (2026). Official source. Includes submission guidance, Secretariat contact and accessibility information. [2] Australian Government Department of Health, Disability and Ageing, NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 - fact sheet (14 May 2026). Official source. Summary of the introduced Bill by Schedule and Part. [3] Australian Government Department of Health, Disability and Ageing, Changes to the NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 - fact sheet (2 July 2026). Official source. Summary of amendments agreed in the House on 1 July 2026. [4] Australian Government Department of Health, Disability and Ageing, About the changes to the NDIS (updated July 2026). Official source. Implementation and consultation information.

[5] Parliamentary Library, Bills Digest: National Disability Insurance Scheme Amendment (Securing the NDIS

for Future Generations) Bill 2026 (25 May 2026). Official source. Preliminary analysis of the introduced Bill, policy context and financial implications. [6] Federal Register of Legislation, National Disability Insurance Scheme Act 2013 - current compilation (6 May 2026 compilation). Official source. Objects and principles, including sections 3, 4, 17A and 31.

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[7] Office of the United Nations High Commissioner for Human Rights, Convention on the Rights of Persons with Disabilities (adopted 2006). Official source. Relevant rights include Articles 3, 4(3), 5, 7, 12, 16, 19, 20, 23, 25, 26, 27, 28 and 30. [8] Law Council of Australia, Submission and concerns regarding the NDIS Future Generations Bill 2026 (8 July 2026). Official source. Concerns regarding consultation, permanence, timeframes, cohort reductions, automation, review rights and access to justice. [9] People with Disability Australia and Disability Representative Organisations, Joint submission of Australia’s Disability Representative Organisations (1 June 2026). Official source. Calls for the Bill not to proceed in its current form pending evidence, safeguards, consultation and operational alternatives.

[10] Carers Australia, Submission to the Senate Community Affairs Legislation Committee on the NDIS Future

Generations Bill 2026 (12 June 2026). Official source. Raises the risk of cost and responsibility shifting to family and friend carers. [11] Parliament of Australia, Bill home page and parliamentary documents (2026). Official source. Bill text, explanatory materials, progress and proposed amendments. [12] United Kingdom Department for Education and Department of Health and Social Care, SEND code of practice: 0 to 25 years (updated 12 September 2024). Official source. The guidance applies to England and describes the Special Educational Needs and Disability and Education, Health and Care plan framework.

[13] United States Centers for Medicare & Medicaid Services, Medicaid and Mandatory & Optional Medicaid

Benefits (accessed 10 July 2026). Official sources. Medicaid is administered by states under federal requirements, and some state-plan benefits are optional. [14] National Disability Insurance Agency, About the NDIS and Guide to getting started (accessed 10 July 2026). Official sources. The NDIS provides individual funding to eligible people with disability through a national statutory scheme. [15] Australian Institute of Health and Welfare, Emergency department care 2024-25 and Time spent in emergency departments (published November 2025 to January 2026). Official sources. Reports 9.1 million emergency presentations, 53 per cent completed within four hours, 30 per cent for presentations ending in admission, and a 90th percentile of 18 hours and 57 minutes for admitted patients. [16] Australian Taxation Office, National Disability Insurance Scheme - GST (13 June 2024). Official source. A supply to an NDIS participant is GST-free where the statutory requirements are met. [17] Australian Taxation Office, Income tax exempt organisations; Tax concessions for ACNC registered religious institutions (accessed 10 July 2026). Official sources. Certain eligible and endorsed organisations may access income-tax exemption. [18] Australian Charities and Not-for-profits Commission, Charity money myths: the facts about operating as a not-for-profit (accessed 10 July 2026). Official source. A charity may undertake commercial activities where those activities are directed to advancing its charitable purposes. [19] National Disability Insurance Agency, Gathering evidence; What is supporting evidence for your patient; and How to prepare for a plan reassessment (current or accessed 10 July 2026). Official sources. Guidance on professional evidence, recency and information used for access and plan reassessment decisions. [20] National Disability Insurance Agency, Participant Service Charter; and What is reasonable and necessary (current or accessed 10 July 2026). Official sources. Describes transparent, responsive, respectful, empowering and connected service and the use of participant evidence in funding decisions. [21] National Disability Insurance Agency, Guide to providing home modifications; How to provide a home modification assessment; and Participant Safeguarding Policy (current or accessed 10 July 2026). Official sources. Covers safety, daily tasks, assessments, supporting evidence, quotations and participant safeguarding. [22] Department of the Prime Minister and Cabinet, Review of COAG Councils and Ministerial Forums; and Department of Social Services, Disability Reform Ministerial Council (current or accessed 10 July 2026). Official sources. Explains the post-COAG intergovernmental structure and the current forum of Commonwealth, state and territory disability ministers reporting to National Cabinet.

[23] National Disability Insurance Agency, Participant Pathway Experience Co-design Working Group - 6 May

2025 (28 May 2025). Official source. Records participant requests to avoid repeating their stories and concerns that planners can arrive unprepared or unaware of disability history.

[24] National Center for Biotechnology Information, GeneReviews, Phelan-McDermid Syndrome-SHANK3 Related

(updated 2024), together with European Reference Network ITHACA, Phelan-McDermid syndrome guideline (accessed 10 July 2026). Expert clinical sources. They describe absent or severely delayed speech, moderate-to profound intellectual disability and uncertain prevalence; the European guideline estimates incidence of at least 1 in 30,000 and considers underdiagnosis likely.

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[25] National Center for Biotechnology Information, GeneReviews, Cantú Syndrome (accessed 10 July 2026). Expert clinical source. It states that incidence is unknown, reports more than 100 molecularly identified individuals in the cited evidence and describes the need for surveillance across relevant body systems. [26] Remuneration Tribunal, Remuneration Tribunal (Members of Parliament) Determination 2024, Compilation No. 4, in force from 1 July 2025, clause 2.8; Australian Government Department of Finance, Ministerial and Parliamentary Services, Electorate allowance (accessed 10 July 2026); and Australian Taxation Office, Taxation Ruling TR 1999/10, Income tax and fringe benefits tax: Members of Parliament (current as accessed 10 July 2026). Official sources. Every senator and House member receives a base electorate allowance of $39,700 per year, with higher amounts for geographically larger House electorates. Parliamentary allowances are generally returned as assessable income, and eligible work-related expenses may be deducted under the applicable tax rules. Thank you for the opportunity to speak our truth.

Regards,

Shannon Manning

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