NDIA Accountability Project

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Reduction of community participation budgets impacting participant isolation (Provider experience)

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Submission 309

Your Choice Supports Pty Ltd

6 Staff Place

Forestdale

QLD 4118

Dear Committee Chair and Members,

Re: Submission to the Inquiry into the National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

YCS is a registered NDIS Provider established in 2015, and operates in the Brisbane-West area. YCS currently provide supports to over 70 participants and employs 70 staff. We provide the following NDIS services:

  • 0104 High Intensity Daily Personal Activities
  • 0106 Assistance in Coordinating or Managing Life Stages, Transitions and Supports
  • 0107 Daily Personal Activities
  • 0108 Assistance with Travel/Transport Arrangements
  • 0115 Assistance with Daily Life Tasks in a Group or Shared Living Arrangement
  • 0116 Innovative Community Participation
  • 0117 Development of Daily Living and Life Skills
  • 0125 Participation in Community, Social, and Civil Activities
  • 0132 Support Coordination
  • 0136 Group and Centre-Based Activities YCS prides itself on being a registered provider since the service was established over 10 years ago. We recently received ‘Best Practice’ for our entire Core Module as part of our Mid-Term Audit. This evidences that we exceed expectations of a NDIS Provider in the quality services we provide. When working with industry partners we are proud of what we do and take any opportunity to showcase the outcomes of the people we support, which they’ve been able to achieve through the support of our staff and their NDIS funding. Unfortunately over the last 12 months especially, we have felt shame where pride used to be when communicating with the wider community as a NDIS registered Provider. We have seen smear campaigns about fraudulent NDIS providers, which has tarnished the name for all quality and reputable providers who are doing the right thing. These fraudulent providers have taken advantage of the scheme, where gaps existed in its conception, so naturally we agree something has to change to return the NDIS back to its initial intentions. However, it is in our professional opinion that the way the Bill is currently written, it targets the wrong areas.

We hold the following serious concerns about components of the proposed Bill.

  1. Social, civic and community participation budgets to be reduced by 50%. Our Concerns:
  • Will cause greater social isolation for participants. Based on our experience, this social isolation will cause a greater reliance on other systems. We have cases that when a participant experiences a decrease in community access their behaviours increase which causes higher rates of hospitalisation or leaving unplanned causing call-out’s to Emergency Services.

______________________________________________________________________________________________ 6 Staff Place – Forestdale – QLD 4118 – Mob +61 435 933 766

ABN: 82607793877

NDIS Provider number 405 000 6232

Submission 309

______________________________________________________________________________________________ The other systems are not ready for an influx of similar cases like this, this means participants who are already vulnerable will become more disadvantaged, isolated and discriminated against due to a lack of services and misunderstanding of support needs.

  • Create a reduction in economic participation due to reduction in spending from participants and the workers who will ultimately lose employment. The NDIS has enabled participants to gain or maintain employment, and for the wider community to be employed. All these workers pay tax and contribute to the economy. In 2021, it was estimated $2.25 was the return-on-investment for every $1 spent on the NDIS. It is expected the current return-on-investment is higher. Based on our experience, when a person loses access to employment, they are at risk of significant impacts on their overall financial and psychological wellbeing. We have supported participants in the past who have experienced job loss and assisted these people to connect with Centrelink and mental health services. The reliance on these systems will only increase due to the reduction of supports and people ultimately losing their employment, wait time’s will lengthen and costs will ultimately not reduce but transfer to other Government systems.

  • Greater expectation for NDIS Providers to offer “free services” more than they currently do. We already have a number of participants access our service who are not eligible for the NDIS but who have nowhere else to go. This expectation to offer free services will only increase as a result of the lack transition planning. In other situations like this, we have had informal supports leave the person at our service as they know under “duty of care” obligations that we have to ensure the safety of the person, ultimately providing services that cannot be invoiced for. We will see an increase of this occurring across the sector due to the increased burnout and fatigue of carers.

  1. Additional Powers to the Minister:

  • to pick any support category and reduce funding by any percentage below 100%.

  • to apply these powers to only a particular cohort of participants and cannot be appealed.

  • Pricing decision-making.

  • to specify the highest amount the NDIS will fund for a particular support and choose to apply these maximums to all participants or to a particular cohort. The maximum funding levels apply even if it is less than the cost of the support.

Our Concerns:

  • Will cause a breach of Human Rights for removing a participant’s opportunity to appeal decisions that have direct impact on their day-to-day life which would lead to significant injury and death. A scheme as big as the NDIS is going to continue to make administrative mistakes, in a process as large scale as this targeting specific cohorts of people, system errors will occur. This will result in unintended people being targeted and their ability to appeal and rectify the NDIA mistake will be taken from them.

  • Lack of transparency, knowledge and awareness by the Minister and the NDIA into specific types of cohorts causing decisions being made about them, without them. We support a number of people with similar diagnosed disabilities, but their support needs differ entirely. It is a dangerous move to make a blanket decision about an entire cohort of people and highly discriminative.

______________________________________________________________________________________________ 6 Staff Place – Forestdale – QLD 4118 – Mob +61 435 933 766

ABN: 82607793877

NDIS Provider number 405 000 6232

Submission 309

  1. Reduction of people being eligible to access the scheme Our Concerns:
  • The proposed Inclusive Communities Fund will be too late, and the current ILC grants are not expansive enough to the wider community. When a minimum of 170,000 people are removed from the scheme there will not be services ready to support them. For over two years, YCS has spent over 70 hours working with one individual to gain access to the NDIS. They live with a permanent neurological impairment which has caused lifelong incontinence, along with the inability to work and experiences significant social isolation. This person has exhausted all mainstream options, and has appealed to the highest point, being ART. This person is still not deemed eligible for the NDIS. If this person is not eligible, what does this mean for all the other people we support with similar support needs already accessing the NDIS? With the proposed changes of removing over 170,000 people from the NDIS, this will cause a significant amount of people left unsupported causing a greater strain on already exhausted services such as health, mental health and welfare. We know this will lead to more social isolation, abuse and discrimination to an already vulnerable cohort of people. We know this will ultimately cost the government more in the future to address.
  1. Support Coordination services being moved to a “commissioning” model / Establish a panel-style arrangement for plan managers through mandatory deed arrangements with the NDIA.

Our Concerns:

  • Reduces the choice and control aspect for participants. Majority of the people we support in this space were exercising their choice and control when choosing YCS as their provider. They had worked with other Support Coordinators that they did not want to continue with. They chose YCS because we pride ourselves on being a quality service.

  • Evidence has shown that participants fall through the gaps in the current LAC model due to high workloads, high turnover and large companies providing all the supports. This leads to greater risk of social isolation, abuse and discrimination to an already vulnerable cohort of people.

  • Lack of transparency for smaller providers to be considered part of this model, including the eligibility criteria and how to be involved in the process.

  • Perception of providers being forced to maintain high registration costs to be able to continue offering services, to then be forced to close services once the commissioning model is established.

  1. SIL services being moved to a “commissioning” model Our Concerns:
  • Reduces the choice and control aspect for participants in terms of providers and the people they live with. We have firsthand experience on what happens when you put incompatible people living together. A person was put in this situation in the previous block funding model, and it resulted in high behaviours such as smearing faeces, hitting the co-tenants and staff, and throwing furniture through windows. When this person transitioned to the current NDIS funding model where choice and control was given, over time there was significant reduction in behaviours and a decrease in authorised restrictive practices in place.

______________________________________________________________________________________________ 6 Staff Place – Forestdale – QLD 4118 – Mob +61 435 933 766

ABN: 82607793877

NDIS Provider number 405 000 6232

Submission 309

______________________________________________________________________________________________ With the NDIS proposing to dictate living arrangements, will they take ultimate responsibility and be prosecuted when significant incidents occur between co-tenants and they only way it could’ve been managed by the people not living together?

  • Risks smaller providers who currently provide quality services to be removed from the sector. Monopolies from only a few big companies is never positive for any market and this is pure economics. These companies will have the financial means and corporate backing to lobby hard against government as they will be the only providers left in the sector. This takes the voice away from people with a disability.

  • Reduction in the person-centered approach, as it will be provided by large companies with multiple layers of delegation, causing participants to slip through the cracks which causes further risks of exploitation, abuse and neglect. We have seen this model, the NDIS was put in place to move away from this model, and now it’s being considered again for pure economic reasons, not to protect people with a disability.

  • Lack of transparency for smaller providers to be considered part of this model, including the eligibility criteria and how to be involved in the process. Currently there seems to be an inner circle of preferred providers and no details on how to be considered in future planning.

  • Perception of providers being forced to maintain high registration costs to be able to continue offering services, to then be forced to close services once the commissioning model is established.

  1. NDIA to computer automate certain administrative actions. Our Concerns:

  • The Centrelink automated system evidenced that these systems do not work, but cost more money in the long-term through the mistakes that occur and legal class-actions taking place after the fact.

  • Further risks to privacy and confidentiality to sensitive participant information being shared with unauthorised people. We have experienced the current NDIS system breach people’s privacy and confidentiality, it will only get worse once key processes are automated.

  1. NDIS to introduce functional capacity assessments to determine a person’s eligibility. After January 2028, all applicants and current participants will need to do one of these assessments. / Fund people only for supports directly attributable to impairments that meet the access criteria.

Our Concerns:

  • The roll-out of the NDIA evidenced that Planners and LAC’s were under-skilled and under-trained with working with people with disability. This caused plans not being fit for purpose leading to higher levels of unscheduled reviews and for people with a disability to take on the administrative burden of upskilling paid staff to understand general information about.

  • These assessments are not fit for all disability types, and will likely have adverse effects on participants with mental health and neurological disabilities as the NDIA does not understand the individual needs of these individuals.

  • The assessments will become a “cookie cutter” approach facilitated by workers who are not qualified, nor independent, and are not free from bias. These assessors may act in the best interest of the NDIA not the individual. ______________________________________________________________________________________________ 6 Staff Place – Forestdale – QLD 4118 – Mob +61 435 933 766

ABN: 82607793877

NDIS Provider number 405 000 6232

Submission 309

  • Nil transparency of what is the listed impairments a person has/hasn’t gone through eligibility which creates further administrative burden on participants with limited access to supports through Support Coordinators, and reduced opportunities to appeal decisions.
  1. That people should not be eligible for the NDIS if there is an alternative system that could support them instead. It outlines that people won’t be eligible for the NDIS if the impairment they are applying for could be covered by a motor vehicle accident compensation scheme or a workplace compensation scheme.

Our Concerns:

  • Lack of transparency on who covers the gap, and what happens if the other system does not cover the entire suite of support required

  • Lack transparency of mainstream scaffolding

  • Unknown if there will be an immediate reduction or transition, with no accessible ready to use resources to support replacement of ceased supports

  1. Civil Penalties and Regulatory Powers to give the NDIA the power to issue compliance and infringement notices and accept enforceable undertakings

Our Concerns:

  • Needs to include all providers, not just registered providers.

  • Where is this workforce coming from? The NDIS Commission and the NDIA are already struggling to keep on top of the current issues.

  • What safeguards are going to be put in place to protect reporting providers? We have had experience of reporting to the NDIS Commission against other providers and then received counter reports (that were unsubstantiated) by the provider as retaliation. This took up valuable resources from not only the NDIS Commission, but us as a company to evidence that appropriate steps were followed.

  • Better communication with smaller providers is required about these changes, especially Support Coordinators and Plan Managers who are reporting alleged fraud to be reviewed.

What needs to be the focus

We agree something needs to be done to align the NDIS with its original intention, but cutting funds from the people who access the scheme is not the answer.

The focus should be on the following proposals in the Bill that address the rampant fraud and ineffective use of funding:

Mandatory registration for high-risk services.

  • This must be prioritised as a matter of urgency. Too many providers are operating with no oversight which leads to higher risks of financial abuse and exploitation. More must be done to remove fraudulent providers from the scheme. This will reduce the cost of the scheme, improve public confidence and perception of the efficiency of the scheme and stop good providers being labelled “greedy and money hungry”. Mandatory registration will assist with this process.

______________________________________________________________________________________________ 6 Staff Place – Forestdale – QLD 4118 – Mob +61 435 933 766

ABN: 82607793877

NDIS Provider number 405 000 6232

Submission 309

______________________________________________________________________________________________ Information needs to be shared on where workforce for Auditors is coming from, and who is overseeing their own compliance. We have worked alongside multiple providers who have obtained registration. Providers who have acted neglectfully of which we have reported to the NDIS Commission. With these allegations of abuse and neglect, how then do these same providers continue to operate and maintain their registration? How did these providers manage to certify for registration in the first place?

YCS prides itself on always being a registered NDIS provider, and upholding quality supports for over 10 years. It is disappointing and disheartening that other providers who continue to do the wrong thing by participants are also considered “registered” under the same umbrella as us, yet the quality of service couldn’t be more different.

Registered plan management providers and their related parties being prohibited from providing other NDIS supports or services.

  • Plan Managers should not be able to pay the invoices for their own company. This type of conflict of interest cannot be effectively managed.

Explore whether leasing equipment is an appropriate option, especially if the person’s personal circumstances are likely to change in a way that would impact their need for the equipment or modifications (e.g. if they have a degenerative condition or are likely to move house).

  • As a service provider, we have supported people through different life stages as their disability progresses, which then means the equipment is no longer fit for purpose. A leasing model would evidence much greater value for money instead of large amount of equipment being unused, or sold for individual profit by the person.

Renewed Plan model rather than the extended/rolled over model.

  • History as shown that when a person’s plan rolls over with leftover funds they become accustomed to that level of funding which was never intended to meet the ‘reasonable and necessary’ criteria. By renewing the plan as a “carbon copy” will assist the person to maintain their supports in line with the intended use.

Differential pricing arrangements for registered and unregistered providers.

  • This would acknowledge that unregistered providers do not have the same overheads as a registered providers. This is due to unregistered providers not having to adhere to the same regulatory compliance requirements as a registered provider.

______________________________________________________________________________________________ 6 Staff Place – Forestdale – QLD 4118 – Mob +61 435 933 766

ABN: 82607793877

NDIS Provider number 405 000 6232

Submission 309

______________________________________________________________________________________________ Final statement

It is in our professional opinion gained through lived experience and operating on the frontline for over a decade, that the Bill in its current form is misguided and targets the wrong areas.

The Bill should focus more on transitioning providers into a “regulated market” rather than the initial “free market” created at the beginning of the scheme.

The Bill should focus on removing fraudulent providers from the sector who are tainting the industry as a whole.

The Bill should focus on creating limitations with participant funding that does not leave a person completely unsupported with no transition plan, this can be achieved through the proposed renewed plan model.

These should be the targets, not targeting the vulnerable people who are making genuine reasonable and necessary use of the scheme.

______________________________________________________________________________________________ 6 Staff Place – Forestdale – QLD 4118 – Mob +61 435 933 766

ABN: 82607793877

NDIS Provider number 405 000 6232