NDIA Accountability Project

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Submission 3082 — Name Withheld — NDIS Future Generations Bill

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Submission on the National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

Personal submission - name withheld Submission from: Name withheld Role: Sole trader provider delivering peer-led, game-based psychosocial and community participation supports Location: Publication request: I request that my personal name and identifying details not be published. Participant privacy: The examples in this submission are real but have been de-identified to protect participants, families and workers. Contact details: Provided separately through the committee submission form and intentionally not included in this public document. Note on use of AI assistance I am making a parliamentary submission for the first time. Writing and structuring a submission is difficult for me, so I have used artificial intelligence tools to help organise, draft and edit this submission. The views, experiences and concerns expressed are my own. I have reviewed this submission and take responsibility for its accuracy.

Summary

I ask the committee to recommend that the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 not proceed in its current form. I support action against fraud, exploitation and unsafe providers. However, I do not believe this Bill properly addresses those problems. My concern is that the Bill risks using a blunt compliance approach that may punish ethical small providers and reduce participant choice, while failing to address business models that can appear compliant on paper but deliver poor value or poor-quality support. The NDIS should not become a system where only large providers can afford to exist. For participants with psychosocial disability, losing small, trusted, relationship-based community supports can mean isolation, disengagement, crisis, hospitalisation and preventable harm. Who I am and what my service does I am a sole trader provider in . I have worked in disability, mental health, peer support and community services for more than ten years, including before the NDIS existed. I hold a dual diploma in community services/community welfare and a Certificate IV in Training and Assessment. My specialist career as a peer practitioner began around 2015. I work from both professional training and lived experience. I use lived experience to create programs for people living with psychosocial disability. My service uses board games, video games, tabletop roleplaying games and elements of gaming to create structured opportunities for participants to practise communication, decision-making, confidence, emotional regulation, problem solving, routine, social connection and community participation. I mainly support adults with psychosocial disability, autism, social anxiety, isolation, trauma history, low confidence and difficulty accessing ordinary community spaces. I provide one-to-one support, gaming groups, video game groups and tabletop roleplaying groups. I do not provide Supported Independent Living, accommodation, personal care, clinical therapy, medical care, support coordination or restrictive practices. Why peer-led game-based support matters My service is not simply playing games. The games are the delivery method for structured psychosocial and community participation support. Games can create a safe, meaningful and non-clinical environment for people who struggle with ordinary social settings. They allow participants to practise communication, turn-taking, boundaries, assertiveness, teamwork, empathy, trust and decision-making in a way that feels less threatening than direct clinical conversation. Many participants with psychosocial disability have long histories with services that feel clinical, institutional or constantly assessment-focused. In my experience, participants often engage better when support feels human, respectful and community-based. This does not mean the support is unstructured. Skilled game-based support requires preparation, facilitation, adaptation, observation, reflection and active management of group dynamics. A poor version of game-based support is placing games in a room and telling people to help themselves. That is not the work I am describing. The value comes from skilled facilitation, lived experience, structure and understanding of

psychosocial disability. Over time I have seen participants build routine, attend more consistently, form friendships, communicate better, become less isolated, regulate emotions more effectively, access the community more confidently, and move toward work, social connection and meaningful relationships. The Bill does not properly distinguish between high-risk and low-risk supports I support removing unsafe providers and addressing fraud. My concern is that the Bill risks treating compliance as the same thing as quality. In my experience, they are not the same. A provider can be compliant on paper and still deliver poor, impersonal or ineffective support. A small provider can be ethical, skilled and trusted by participants while still being unable to afford heavy compliance systems designed for larger organisations. Unregistered does not mean unregulated. Unregistered NDIS providers are already subject to the NDIS Code of Conduct. My concern is not with reasonable obligations such as privacy, safe and competent support, honesty, transparency, and preventing abuse, neglect and exploitation. My concern is with reforms that may treat small unregistered providers as unsafe by default, instead of creating proportionate pathways based on the actual risk of the support being delivered. Community participation and peer-led psychosocial supports should not be treated like SIL, accommodation, restrictive practices, high-intensity personal care, behaviour support or clinical services. A fair system must separate these categories properly. The problem with group pricing A major issue for my service is the way NDIS group pricing treats group support. The NDIS Pricing Arrangements and Price Limits 2025-26 state that when a support item is delivered to more than one person at the same time, the price limit for each participant is generally the applicable price limit divided by the number of people in the group. The NDIS Pricing Schedule 2026-27 lists Group Activities - Standard - Weekday Daytime (04_102_0136_6_1) at $73.58 per hour nationally. In practice, this does not reflect the complexity of psychosocial group work. The group is the setting, but the support is still individualised. Each participant may have different goals, communication needs, trauma responses, social barriers, cognitive strengths, emotional regulation needs, sensory needs, confidence levels and risks around isolation or disengagement. In a skilled psychosocial group, the provider is constantly adapting communication, pacing, rules, prompts, emotional support and participation opportunities so each person can safely engage. A one-size-fits-all group split assumes that because participants are in the same room or online session, the support effort is evenly divided. That is not how skilled psychosocial group support works. I currently charge around $64 per hour and have not had a meaningful increase since around 2021. Even when the official price limit increases, many participants cannot afford the higher rate because of limited or reduced funding. In reality, I often undercharge to keep the service accessible. This means the provider carries the full complexity of the group while being paid as though the work is a simple divided activity. That is not sustainable. Current NDIS direction before this Bill The impact of this Bill must also be considered in the context of changes already occurring in the Scheme. The NDIA June 2025 Financial Sustainability Report states that in 2024-25, 83% of non-mortality exits from the Scheme were due to Agency-initiated eligibility reassessments. It also states that 43,500 participants were due for an eligibility reassessment at 30 June 2025, and that exits are projected to increase to between 23,200 and 27,300 exits per year over the next three years as the reassessment backlog is processed. Participants leaving the Scheme are not simply statistics. For many people with psychosocial disability, removal or reduction of supports can mean increased isolation, deterioration, crisis presentations, hospitalisation, family breakdown and preventable harm. The same report also discusses participant deaths as part of Scheme forecasting. I understand that actuarial reports use this language for forecasting, but for participants, families, carers and frontline providers, these are people’s lives. The committee should consider not only whether reforms reduce expenditure, but whether they increase risk elsewhere. Impact on participants and small providers Participants do not all respond to large, clinical, mainstream or centre-based services. Some need small, familiar, human environments. Some are triggered by spaces that feel like hospitals or institutions. For many participants, the non-clinical nature of my service is not an extra feature. It is the reason they can attend. If small providers disappear, participants will not simply move smoothly to large providers. Some will disengage. Some will become more isolated. Some will lose one of the only structured social spaces they have. When community support is reduced, the cost does not disappear. It can return later as crisis, hospitalisation, family breakdown, emergency service use and preventable harm.

Small providers and sole traders are also under pressure. We face rising rent, transport, insurance, unpaid planning, unpaid administration, preparation time, cancellations, plan changes and uncertainty. For game-based and tabletop roleplaying supports, preparation can include learning and modifying games, creating aids, adapting content for disability needs, managing group dynamics, writing notes and reflecting on what each participant is working toward. Sometimes the real work required goes beyond the funded time available. If one participant leaves or cannot afford a group, the group can become financially unstable for everyone. Participants are often effectively relying on each other to keep a service viable. That is not fair on participants or providers. If the Bill increases compliance costs, audit burden or administrative requirements without a realistic low risk pathway, providers like me may leave the sector. That would not improve participant safety. It would remove skilled, experienced, local support. Future consequences If this Bill proceeds without major changes, I am concerned the consequences will be severe. More participants with psychosocial disability may experience distress, isolation and disengagement from supports. Some may present more often to hospitals or crisis services. More skilled sole traders and small providers may leave NDIS work because they cannot afford registration, audits, compliance systems and unpaid administrative burden. Innovative supports such as gaming groups, tabletop roleplaying groups, peer-led programs and non-clinical social participation may be pushed out of the funded sector and left to volunteers. That is not sustainable. Skilled disability work should not depend on unpaid labour, especially during a cost-of-living crisis. Participants deserve stable, skilled, properly paid workers. Providers deserve a viable way to keep delivering support. If the NDIS market becomes one where only large providers can survive, the Scheme will become less personal, less flexible and less connected to local communities. That would not secure the future of the NDIS. It would weaken it.

Recommendations

  1. That the committee recommend the Bill not proceed in its current form.

  2. That any reform create a clear, affordable and proportionate low-risk registration or enrolment pathway for small providers, sole traders, peer-led services and community participation providers.

  3. That community participation and psychosocial peer-led supports be treated differently from SIL, accommodation, restrictive practices, high-intensity personal care, behaviour support and clinical services.

  4. That compliance and audit requirements be scaled to provider size, service type and actual risk.

  5. That participant choice be protected, including the right to choose small, local, peer-led, culturally suitable and non-clinical providers.

  6. That gaming and tabletop roleplaying be recognised as legitimate support delivery methods when used by skilled providers to achieve disability-related goals.

  7. That the Government provide transition support and clear guidance before introducing any reforms that increase obligations on small providers.

  8. That community participation be recognised as preventative support, not an optional extra.

  9. That reform target actual fraud, exploitation and poor-quality practice, not simply increase administrative burden for ethical providers. Closing statement The NDIS was not created only to manage risk. It was created to support people with disability to live ordinary, connected and meaningful lives. For people with psychosocial disability, connection is not a luxury. Community is not a bonus. Human support is not an optional extra. A system designed to catch bad actors must not accidentally remove the small, skilled, relationship-based providers who are keeping participants connected, safe and engaged. This Bill should not proceed in its current form. It must be changed so that it protects participants without destroying the small providers many participants rely on. Source notes  NDIA, NDIS Pricing Arrangements and Price Limits 2025-26, Version 1.1, effective 24 November 2025, especially the group-based support rules and support categories.  NDIA, NDIS Pricing Schedule 2026-27, effective 1 July 2026, especially Schedule 1, Group Activities - Standard Weekday Daytime (04_102_0136_6_1).  NDIA, June 2025 Financial Sustainability Report / Annual Financial Sustainability Report 2024-25, including reported Agency-initiated eligibility reassessments, reassessment backlog, projected exits and mortality assumptions.  NDIS Quality and Safeguards Commission, NDIS Code of Conduct guidance and correspondence to unregistered providers.