Practice Frameworks, Human Rights, Choice and Control (Individual advocacy) | External submission

Submission 312

Submission to the Senate Community Affairs Legislation Committee

Inquiry into the National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

Submitted by: Developing Ur Life

Port Pirie, South Australia

Prepared by Emma Nunan

Director | Bachelor of Social Work | Master of Disability Policy and Practice |

Developmental Educator

Date: 26 May 2026

Developing Ur Life – Senate Submission 2026 1

Submission 312

Contents:

Foundational Position and Core Thesis
Executive Summary
About Developing Ur Life
Evidence Base and Practice Frameworks
Human Rights, Choice and Control
Governance, Administration Powers and Legislative Concerns
Automation, Standardisation and Complexity
Preventative Systems versus Crisis Systems
Children Adolescents and Intergenerational Impact
The Hidden Economy of Care
Regional and Remote Systems Collapse Risk
Market Stewardship and Thin-Market Failure
Functional Capacity Assessments and Administrative Contradictions
Psychosocial Disability and Fluctuating Capacity
Adversarial Review Processes and the AAT/ART
Restrictive Practices, Institutionalisation and Safeguarding
Workforce Sustainability and Moral Injury
Co-Design and Consultation Concerns
De-Identified Practice Examples
Recommendations
Conclusion
References Developing Ur Life – Senate Submission 2026 2

Submission 312

Foundational Position and Core Thesis Developing Ur Life submits that the proposed reforms risk fundamentally transforming the NDIS from a preventative, developmental, rights-based and community inclusion framework into a restrictive crisis-management system that may ultimately increase long-term social, economic and human costs.

This submission is not merely opposition to administrative reform. It is a warning regarding the broader societal consequences that may arise when disability systems shift away from prevention, inclusion and developmental support toward increasingly restrictive eligibility frameworks, reduced community participation and heightened administrative burden.

The proposed reforms represent a broader ideological shift in how Australia conceptualises disability, participation, safeguarding, citizenship, support and human value.

Developing Ur Life strongly submits that disability support is not discretionary expenditure. It is essential social infrastructure that enables:

community inclusion
educational participation
workforce participation
safeguarding
independence
long-term societal stability

Executive Summary Developing Ur Life (DUL) strongly opposes the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 in its current form.

While we acknowledge the importance of Scheme sustainability, sustainability cannot be achieved by narrowing access to supports, reducing preventative intervention, restricting developmental and psychosocial supports, or shifting risk onto participants, families, providers and an already overwhelmed crisis system.

The proposed reforms risk:

increasing social isolation and exclusion
destabilising regional service systems
increasing safeguarding concerns
increasing hospitalisation and homelessness Developing Ur Life – Senate Submission 2026 3

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increasing justice system involvement
worsening workforce shortages
increasing institutionalisation risk
reducing long-term independence
increasing intergenerational disadvantage The impact of these reforms will extend far beyond people with disability. Families, schools, hospitals, mental health systems, police, homelessness services, child protection systems and regional communities will absorb the consequences of reduced support access.

About Developing Ur Life Developing Ur Life (DUL) is a regional South Australian disability provider based in Port Pirie, delivering support across rural and regional communities characterised by persistent thin-market conditions, structural disadvantage, and service system fragmentation.

DUL provides support to participants with psychosocial disability, autism, intellectual disability, developmental delay, trauma-related presentations, neurodevelopmental conditions, and complex behavioural and safeguarding profiles. In practice, these presentations are rarely singular in nature. Participants frequently experience co-occurring and intersecting forms of disadvantage that shape both the severity and trajectory of support need.

These intersections commonly include:

psychosocial disability and mental health complexity
trauma exposure and intergenerational trauma
socioeconomic disadvantage and entrenched poverty
housing instability and homelessness risk
family violence and safeguarding vulnerability
substance use and dependency
justice system involvement or diversionary contact
educational disengagement and disrupted developmental pathways
geographic isolation and rural service exclusion
limited workforce availability and service market failure Developing Ur Life operates from a contemporary intersectional and structural determinants framework, recognising that disability is not a discrete or isolated condition, but is produced and compounded through the interaction of individual impairment, environmental barriers, and systemic inequities. Within this framing,

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disability outcomes are shaped as much by service accessibility, housing security, social inclusion, and system responsiveness as they are by diagnostic categorisation or clinical presentation.

DUL further applies ecological systems theory and biopsychosocial formulation approaches, recognising that functioning is context-dependent, relational, and dynamic. Participant capacity is frequently influenced by environmental instability, trauma triggers, service continuity, social connection, and the availability of preventative and developmental supports. As such, static or snapshot assessment approaches often fail to adequately represent real-world functional need.

As a regional provider operating within thin markets, Developing Ur Life works in contexts where service scarcity is not theoretical but structural. Participants in these settings often experience limited or no meaningful provider choice, extended wait times, and fragmented service pathways. In some instances, the withdrawal or absence of a single provider or clinician can materially destabilise entire regional support ecosystems, with direct consequences for participant safety, housing stability, and crisis escalation risk.

DUL operates at the interface of multiple system domains, including disability support, psychosocial and mental health systems, housing and homelessness services, child protection, education, acute health services, and justice-related systems. This positioning reflects the reality that disability support in regional Australia is inherently cross-system and interdependent, rather than siloed within a single service domain.

Accordingly, Developing Ur Life is not only a service delivery organisation, but a frontline systems interface entity, generating practice-based evidence from within complex, high-risk, and resource-constrained environments. This includes direct observation of how policy settings, administrative frameworks, and funding structures translate into real-world outcomes for participants, families, and regional service systems.

Our practice is grounded in:

trauma-informed systems and care frameworks
human rights-based disability approaches consistent with the UN Convention on the Rights of Persons with Disabilities
psychosocial rehabilitation and recovery-oriented practice
developmental and neurodiversity-affirming approaches
safeguarding and risk ecology frameworks Developing Ur Life – Senate Submission 2026 5

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strengths-based and relational models of practice
ecological and systems-based formulations of disability and support need Within this framework, Developing Ur Life does not conceptualise disability as an issue appropriately resolved by external system referral alone. Rather, we recognise disability support as an essential and foundational component of Australia’s social infrastructure, integral to the functioning of multiple interconnected systems including health, housing, education, and justice.

Importantly, in regional and remote contexts, the National Disability Insurance Scheme is not one system among many; it is often the primary enabling mechanism through which individuals access preventative, developmental, and stabilising supports. The effectiveness of adjacent systems is therefore frequently contingent upon the accessibility and adequacy of disability supports rather than separable from them.

Developing Ur Life’s submission is informed by extensive frontline experience demonstrating that when preventative and developmental disability supports are reduced, delayed, or restricted, there is a corresponding and measurable escalation in demand across acute and crisis-oriented systems, including hospitals, emergency departments, homelessness services, and justice-related pathways. These outcomes are not indicative of system substitution, but of system displacement and downstream escalation.

As such, Developing Ur Life submits that disability support must be understood as preventative systems infrastructure, not residual or supplementary services. They function as a stabilising mechanism that mitigates escalation into higher cost, higher-risk service domains and support long-term participation, safety, and inclusion.

Developing Ur Life therefore asserts that any reform to the NDIS must be evaluated not only through fiscal or administrative lenses, but through a comprehensive cross-system impact framework, particularly in relation to regional and thin-market environments where service interdependence is most acute.

This submission reflects both embedded practice experience and systems-level analysis of disability support within regional Australia, and is grounded in the lived realities of participants, families, carers, and workforce members operating within increasingly complex and constrained service environments.

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Developing Ur Life’s position is that sustainable disability policy must be designed in recognition of:

the structural and intersectional nature of disability and disadvantage
the interdependence of service systems rather than their separability
the centrality of preventative supports in avoiding crisis escalation
and the critical role of regional providers in maintaining system continuity and safety

Accordingly, DUL strongly submits that disability support is a core component of national social and economic infrastructure and must be preserved and strengthened to ensure long-term system sustainability, equity of access, and reduction in intergenerational disadvantage.

Evidence Base and Practice Frameworks This submission is informed by:

frontline disability practice across regional South Australia
trauma-informed practice frameworks
developmental and neuroscience research
psychosocial disability and recovery-oriented practice
safeguarding and behavioural support frameworks
the WHO International Classification of Functioning, Disability and Health (ICF)
findings of the Disability Royal Commission
Australia’s obligations under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD)
evidence regarding rural and remote inequity and thin-market disability service delivery

The concerns raised throughout this submission reflect the lived realities of participants, families, carers and providers navigating systems already under significant strain.

Human Rights, Choice and Control The NDIS was established as a rights-based reform grounded in the principles of choice, control, inclusion and participation.

Australia’s obligations under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD) require systems that promote:

autonomy Developing Ur Life – Senate Submission 2026 7

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inclusion
independent living
participation
dignity
equal access to supports Developing Ur Life is deeply concerned that the proposed reforms risk shifting the Scheme away from participant-directed support toward increasingly centralised administrative control.

The principles of choice and control risk being undermined where:

eligibility becomes increasingly restrictive
assessments become overly standardised
administrative discretion expands
participant voice is reduced
support flexibility decreases People with disabilities must remain active decision-makers within their own lives rather than passive recipients of administratively determined systems.

Governance, Administrative Powers and Legislative Concerns Developing Ur Life holds significant concerns regarding the broad administrative and governance powers proposed within the reforms.

The Bill creates uncertainty regarding:

assessment implementation
operational interpretation
consistency of decision-making
scope of administrative discretion
review and oversight processes Increased administrative discretion without corresponding transparency and accountability mechanisms risks:
inconsistent planning outcomes
reduced participant trust
procedural unfairness
reduced transparency
increased barriers for vulnerable participants Developing Ur Life – Senate Submission 2026 8

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Developing Ur Life is concerned that broad discretionary powers combined with vague operational detail may create significant uncertainty for participants, families and providers attempting to navigate already complex systems.

Automation, Standardisation and Complexity The increasing emphasis on “objective” and “consistent” assessment frameworks raises concern regarding growing reliance on standardisation and potentially automated decision-making processes.

Human functioning, trauma, psychosocial disability and adaptive capacity cannot be fully understood through narrow standardisation or administrative simplification.

Many participants:

mask disability presentation
fluctuate significantly in functioning
present differently across environments
experience episodic deterioration
require relational and contextual assessment Over-reliance on standardised frameworks risks reducing complex human experience into administrative categories that fail to capture:
trauma impact
psychosocial vulnerability
environmental disadvantage
behavioural complexity
safeguarding concerns
relational functioning Disability cannot be accurately understood through snapshot assessments alone.

Preventative Systems Versus Crisis Systems A core concern within the proposed reforms is the apparent shift away from preventative and developmental disability support toward increasingly reactive crisis-management approaches.

Preventative supports such as:

psychosocial intervention
behavioural support Developing Ur Life – Senate Submission 2026 9

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community participation
developmental intervention
capacity building reduce long-term reliance on:
hospitals
emergency departments
homelessness services
justice systems
child protection systems
inpatient mental health systems When preventative systems are weakened, crisis systems expand.

The true measure of sustainability is not annual expenditure reduction, but whether Australians with disability become:

safer
more independent
more included
less reliant on crisis systems over the course of their lives.

Children, Adolescents and Intergenerational Impact Children with autism, developmental delay, psychosocial vulnerability, trauma histories and intellectual disability require timely developmental and relational intervention during critical developmental periods.

Restricting developmental supports risks increasing:

school disengagement
educational exclusion
behavioural escalation
family breakdown
mental health deterioration
future justice system involvement Developing Ur Life is deeply concerned regarding the long-term intergenerational consequences of unsupported disability.

When supports are inadequate:

parents reduce workforce participation
poverty risk increases Developing Ur Life – Senate Submission 2026 10

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siblings assume caring roles
chronic stress increases
future educational opportunities decline The long-term consequences extend across generations and impact:
future workforce participation
economic security
housing stability
mental health outcomes
community wellbeing

The Hidden Economy of Care The disability sector is sustained not only through funded supports, but through a vast hidden economy of unpaid care, advocacy and emotional labour.

Families, particularly mothers and primary carers, frequently:

leave employment
reduce workforce participation
provide unpaid full-time care
coordinate complex systems
absorb financial and emotional burden Providers also absorb substantial invisible costs through:
unpaid advocacy
crisis intervention
safeguarding responses
extended support delivery during funding delays
administrative burden A sustainable NDIS cannot continue relying upon invisible unpaid labour while simultaneously reducing formal support systems.

Regional and Remote System Collapse Risk Regional disability systems are already operating at or beyond sustainability thresholds.

Many rural communities have:

only one provider willing to deliver complex supports
minimal allied health availability Developing Ur Life – Senate Submission 2026 11

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limited SIL availability
limited crisis accommodation
extensive waitlists
severe workforce shortages The withdrawal or collapse of even one provider or clinician may destabilise entire regional systems.

Without targeted safeguards, the proposed reforms risk:

service deserts
participant displacement
increased hospitalisation
institutionalisation
heightened safeguarding risk
greater reliance on police and emergency systems Regional disability systems cannot absorb indefinite instability without broader community consequences.

Market Stewardship and Thin-Market Failure Developing Ur Life is concerned that the reforms insufficiently address the NDIA’s responsibilities regarding market stewardship, particularly within regional and thin-market settings.

Regional providers operate within fragile environments characterised by:

workforce shortages
rising operational costs
travel burden
limited provider competition
increasing participant complexity Where pricing, funding and administrative burden become unsustainable, providers may withdraw from service delivery entirely.

This creates significant risk of thin-market failure whereby participants have little or no access to:

behavioural support
psychosocial intervention
allied health
Supported Independent Living Developing Ur Life – Senate Submission 2026 12

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developmental support A sustainable NDIS requires active investment in market stability rather than assuming market resilience within already fragile regional systems.

Functional Capacity Assessments and Administrative Contradictions The NDIS already routinely relies upon internationally recognised assessment tools including:

Vineland Adaptive Behavior Scales
Adaptive Behavior Assessment System (ABAS)
Functional Capacity Assessments
Multidisciplinary allied health reporting Despite this, participants are frequently required to repeatedly obtain updated evidence while simultaneously experiencing prolonged NDIA delays.

Participants are often required to repeatedly prove permanent disability despite extensive existing evidence.

This creates a systemic contradiction whereby:

clinicians reproduce evidence repeatedly
families experience advocacy fatigue
providers absorb escalating administrative burden
NDIA processing remains delayed In regional communities, repeated reassessment requirements divert already limited allied health resources away from direct therapeutic intervention into administrative report production.

Psychosocial Disability and Fluctuating Capacity Psychosocial disability is not static.

Participants may experience periods of:

stability
deterioration
crisis
recovery
regression Developing Ur Life – Senate Submission 2026 13

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Functioning may fluctuate significantly depending on:

stress
trauma triggers
housing stability
social support
environmental safety Snapshot assessments frequently fail to capture the fluctuating and episodic nature of psychosocial disability.

Developing Ur Life is concerned that restrictive eligibility frameworks and standardised assessment approaches that does not consider the fluctuations people experience, risk excluding participants whose disability presentation varies over time.

Recovery-oriented and trauma-informed practice requires flexibility, relational understanding and responsiveness to changing support needs.

Adversarial Review Processes and the AAT/ART Developing Ur Life holds significant concerns regarding the adversarial nature of review and appeal processes within the NDIS system, including matters progressing through the former AAT and current ART processes.

Participants frequently enter prolonged disputes regarding supports that are clinically recommended and functionally necessary, including:

wheelchairs
assistive technology
Supported Independent Living
psychosocial supports
behavioural intervention These processes frequently involve:
repeated assessments
report duplication
legal representation
tribunal proceedings Substantial public expenditure is directed toward:
legal representation
tribunal administration Developing Ur Life – Senate Submission 2026 14

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repeated evidence review
duplicated assessments while participants may remain without essential support, increasing reliance on crisis systems.

This creates a significant contradiction between stated sustainability goals and ongoing adversarial expenditure.

Restrictive Practices, Institutionalisation and Safeguarding The Disability Royal Commission identified significant safeguarding risks associated with:

social isolation
fragmented systems
inadequate advocacy
institutionalisation
exclusion from community participation Developing Ur Life is deeply concerned that reductions to:
community participation
behavioural support
psychosocial intervention
developmental supports
SIL funding may unintentionally increase:
restrictive practices
institutionalisation
homelessness
justice system involvement
safeguarding failures Community participation and relational support are not optional extras. They are protective safeguards against abuse, neglect, exploitation and social exclusion.

Workforce Sustainability and Moral Injury The disability workforce is increasingly being placed in ethically unsustainable positions.

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Providers and frontline workers are frequently required to balance:

participant safety
safeguarding obligations
workforce shortages
delayed NDIA decisions
financial viability This creates substantial moral injury and ethical distress for workers attempting to maintain safe and ethical support environments within increasingly strained systems.

The sustainability of the disability workforce cannot continue relying upon:

burnout
unpaid labour
crisis management
ethical compromise Without workforce sustainability, participant safety and continuity of care are compromised.

Co-Design and Consultation Concerns Developing Ur Life holds concern regarding the limited timeframe available for meaningful consultation regarding reforms of this scale and significance.

Meaningful co-design requires:

genuine engagement with people with disability
inclusion of regional voices
consultation with frontline providers
engagement with families and carers
consideration of psychosocial and developmental disability perspectives Large-scale structural reform cannot be effectively designed through limited consultation processes that fail to adequately incorporate lived and frontline experience.

De-Identified Practice Examples

Case Example 1 – Child and Adolescent Developmental Support

A young participant with autism, developmental delay and trauma history experienced severe school disengagement, emotional dysregulation and

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behavioural escalation. Through consistent developmental intervention, the participant demonstrated improvements in communication, emotional regulation and school participation.

Case Example 2 – Psychosocial Disability and Housing Stability

An adult participant with psychosocial disability appeared superficially capable during formal appointments. However, without ongoing support they were unable to maintain housing stability, emotional regulation or personal safety.

Case Example 3 – Unsupported SIL Funding Delays

A participant with intellectual disability and autism remained within Supported Independent Living despite prolonged NDIA funding delays. The provider continued delivering support at substantial financial loss to prevent homelessness and safeguarding risks.

Case Example 4 – Rural Allied Health Scarcity

A participant requiring behavioural and developmental intervention experienced prolonged delays due to workforce shortages and limited specialist availability, resulting in escalating family stress and increased risk of placement breakdown.

Recommendations Developing Ur Life recommends that the Senate Committee:
Reject reforms that reduce community participation and capacity-building support.
Undertake comprehensive rural and remote impact assessments prior to implementation.
Introduce rural loading and thin-market protections.
Ensure multidisciplinary, trauma-informed and longitudinal evidence remains central to assessment processes.
Protect developmental and early intervention supports for children and adolescents.
Ensure psychosocial disability and fluctuating conditions are not disadvantaged through restrictive eligibility criteria.
Reduce evidence duplication and improve NDIA processing timeframes.
Reform adversarial review processes and prioritise collaborative early resolution pathways.
Protect multidisciplinary allied health approaches within the NDIS.
Continue recognising Developmental Educators and Social Workers as essential allied health professionals.

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Recognise provider sustainability as a safeguarding issue.
Strengthen transparency and accountability regarding administrative decision-making.
Ensure automation and standardisation do not replace contextual and relational assessment.
Undertake genuine co-design with people with disability, families, regional providers and frontline workers before implementing major reforms.
Conclusion The proposed reforms risk fundamentally reshaping Australia’s disability system in ways that may increase long-term social, economic and human cost.

A sustainable NDIS cannot be achieved by narrowing access to preventative and developmental supports while increasing downstream burden across:

hospitals
mental health systems
homelessness services
justice systems
families
regional communities The true measure of sustainability is not annual expenditure reduction.

It is whether Australians with disability are:

safer
more included
more independent
more connected to community
less reliant on crisis systems over the course of their lives

Developing Ur Life strongly urges the Senate Community Affairs Legislation

Committee to reject reforms that undermine participant wellbeing, increase inequity and place vulnerable Australians at greater risk.

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References

Australian Government Department of Health and Aged Care. (2026). NDIS

Amendment (Securing the NDIS for Future Generations) Bill 2026 Fact Sheet.

Australian Institute of Health and Welfare (AIHW). (2024). People with disability in Australia.

Centre on the Developing Child at Harvard University. (2021). InBrief: The Science of Early Childhood Development.

Herman, J. (2015). Trauma and Recovery.

National Rural Health Alliance. (2023). Disability Services in Rural and Remote

Australia.

Perry, B. D., & Szalavitz, M. (2017). The Boy Who Was Raised as a Dog.

Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. (2023). Final Report.

United Nations. (2006). Convention on the Rights of Persons with Disabilities.

van der Kolk, B. (2014). The Body Keeps the Score.

World Health Organization. (2001). International Classification of Functioning,

Disability and Health (ICF).

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