NDIA Accountability Project

Concerns regarding reforms impacting hearing loss support needs

‹ PrevPage 1 of 11 · Source p. 1Next ›

8 audiology australia

SUBMISSION:

INQUIRY INTO THE NATIONAL DISABILITY INSURANCE SCHEME AMENDMENT (SECURING THE NDIS FOR FUTURE GENERATIONS) BILL 2026

MAY 2026

Audiology Australia Submission:

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Introduction

Audiology Australia welcomes the opportunity to provide a submission to the Senate Community Affairs Legislation Committee regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

Audiology Australia is the peak professional body for audiologists in Australia and represents 94% of audiologists currently working across private practice, hospitals, universities, government, education, disability, aged care and community sectors. Audiologists play a critical role in supporting people with hearing and balance disorders across the lifespan. This includes assessment, diagnosis, rehabilitation, hearing technology prescription and management, communication support and early intervention services for people with permanent and significant hearing-related disability.

Audiology Australia supports efforts to improve the long-term sustainability, integrity and effectiveness of the National Disability Insurance Scheme (NDIS). We acknowledge that these reforms arise in the context of the Independent Review into the NDIS and the Disability Royal Commission, both of which identified challenges relating to sustainability, consistency, participant safeguards and service quality.

However, we have significant concerns regarding the potential unintended consequences of several proposed reforms for people with hearing loss and related communication and participation support needs.

Hearing loss is often an invisible disability whose impacts may be underestimated within systems focused primarily on visible or physical disability. While hearing aids, cochlear implants and rehabilitation can significantly improve access to sound and support communication and participation outcomes for many individuals, they do not restore typical hearing or eliminate the functional impacts of hearing loss. Rather, these interventions form part of an ongoing support pathway to manage a lifelong disability, often alongside additional supports that enable communication and participation. Despite these interventions, many individuals continue to experience substantial functional limitations in complex listening environments, workplace and education settings, as well as in social contexts. The communication and participation impacts of hearing loss can affect language development, educational attainment, employment participation, mental wellbeing, safety and social inclusion. Communication capacity is imperative for participation in individual engagement with health professionals when treating all health conditions.

AUDIOLOGY AUSTRALIA SUBMISSION:

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

disability impacts are contextual, fluctuating or difficult to measure using standardised assessment tools.

Key concerns:

  • Inappropriate or limiting functional capacity assessments that ignore important environmental and contextual factors
  • Strict evidence requirements, including over-reliance on high level peer reviewed evidence that ignores real world clinical expertise and limitations in some areas of disability research including in APD, neurodevelopmental conditions and in female and indigenous populations
  • Reduced access to supports through narrower eligibility and exclusion of those who can’t afford to ‘exhaust all options’
  • Funding risks where the scheme is able to fund below what is determined to be reasonable and necessary and cuts to capability-building supports
  • Expanded ministerial powers with limited oversight that risks undermining participants rights, choice and control
  • Reduced safeguards through limits to reassessments and automation of reviews
  • Flow on impacts to other already underfunded services and systems or where access is difficult.

INTERACTION BETWEEN THE NDIS AND HEARING FUNDING SYSTEMS

People with hearing loss already navigate multiple funding systems, including the Commonwealth Hearing Services Program (HSP), industrial schemes, private and public health services and the NDIS.

Current arrangements already distinguish between hearing supports funded through the HSP and additional disability-related supports funded through the NDIS.3 Many children and young people under 26 years of age with hearing loss access hearing devices and core hearing services through the HSP. However, the NDIS continues to play an important role in funding additional disability-related supports, including communication, participation and multidisciplinary supports for children and adults with complex needs.

We are concerned that reforms intended to strengthen boundaries between the NDIS and mainstream systems may unintentionally create service gaps, duplication, administrative complexity and inconsistent decision-making regarding responsibility for

3

AUDIOLOGY AUSTRALIA

P: 03 9940 3900 | E: info@audiology.asn.au W: www.audiology.asn.au

O audiology australia

AUDIOLOGY AUSTRALIA SUBMISSION:

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

hearing-related supports. Without clear delineation, there is a significant risk of cost- shifting between the NDIS and the HSP, resulting in participants losing access to necessary support rather than achieving system efficiency.

This is particularly significant for participants requiring supports that extend beyond hearing devices themselves, including communication supports, auditory training, assistive listening technologies, participation supports, and multidisciplinary intervention, as is typically the case for those with co-morbidities such as autism spectrum disorder (ASD), auditory processing disorder (APD) and other neurological or communication differences.

Recommendation 1:

Audiology Australia recommends that implementation guidance clearly articulates the interface between the NDIS and hearing-related mainstream systems to ensure participants do not experience gaps in access or continuity of care.

SCHEDULE 1 — ACCESS AND PLANNING MEASURES

Functional capacity

Audiology Australia acknowledges the Government’s intention to create more consistent and evidence-based access decisions through functional capacity assessment. However, there is a significant risk that hearing-related disability and communication participation restrictions may not be adequately recognised within generic or standardised functional assessment models unless hearing-specific expertise is incorporated.

Hearing loss affects communication, education, employment, social participation, cognitive load, safety and mental health. These impacts frequently persist despite intervention and hearing technology. Hearing-related disability is highly contextual. Functional impacts vary significantly depending on communication demands, environmental conditions, fatigue, co-occurring conditions and access to support. This means that two individuals with similar hearing profiles may have significantly different functional support needs.

Communication and participation limitations cannot be adequately understood through audiometric thresholds alone. Functional impacts may differ significantly depending on educational, occupational and social environments

AUDIOLOGY AUSTRALIA

P: 03 9940 3900 | E: info@audiology.asn.au W: www.audiology.asn.au

O audiology australia

AUDIOLOGY AUSTRALIA SUBMISSION:

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Contemporary hearing technologies improve access to sound and communication participation for most but do not fully restore typical hearing. Many individuals continue to experience listening fatigue, difficulty understanding speech in noise, communication breakdowns and reduced social participation.

For children, hearing loss can have lifelong effects on language acquisition, literacy, learning and social development where timely and appropriate interventions and supports are not available.1,2 Reducing access to these supports risks increased long- term costs across education, health and social systems.

We are concerned that standardised functional assessment models may not adequately recognise communication disability or the lived experience of hearing loss unless hearing-specific expertise and communication participation measures are incorporated into assessment frameworks.

The proposal to strengthen the link between impairment and supports may unintentionally narrow access to supports that address broader communication participation impacts associated with hearing loss, including educational participation, social participation, self-advocacy and communication rehabilitation.

Recommendation 2:

Audiology Australia recommends that hearing-related communication and participation limitations be explicitly recognised within functional assessment frameworks and that communication participation measures be incorporated into assessment methodologies.

Defining permanence

We are also concerned regarding proposed changes to the definition of permanence. While hearing technologies and rehabilitation can significantly improve outcomes, many individuals continue to experience substantial and lifelong functional impacts despite treatment.

There is a risk that hearing loss may increasingly be viewed as “treatable” rather than permanently disabling with ongoing disability-related needs, particularly for participants with moderate but functionally significant hearing loss, fluctuating conditions, dual disability or complex communication needs. Hearing aids, cochlear implants and rehabilitation should not be viewed solely as “treatment” that resolves impairment. Instead, they represent one component of an ongoing support pathway for individuals

5

AUDIOLOGY AUSTRALIA

P: 03 9940 3900 | E: info@audiology.asn.au W: www.audiology.asn.au

O audiology australia

AUDIOLOGY AUSTRALIA SUBMISSION:

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

with lifelong hearing-related disability. Even with optimal technology, many individuals continue to experience limitations in communication, participation and functional capacity, necessitating ongoing supports beyond devices alone.

Supports that address communication and participation needs arising from hearing loss meet the “reasonable and necessary” criteria where they are effective, value for money, and enable social and economic participation. These supports should not be excluded on the basis that hearing technology has been provided.

Recommendation 3:

Audiology Australia recommends that legislation and associated instruments explicitly recognise that treatment and assistive technology do not necessarily eliminate the need for ongoing disability-related support needs.

All appropriate treatments

We consider that the requirement to demonstrate “all appropriate treatments” raises equity concerns for people with hearing loss, particularly where access, cost or availability may limit treatment uptake. Audiology Australia recommends that this be limited to treatments that are reasonably accessible and affordable, and that individuals retain the right to decline treatment.

The proposed requirement also raises important implementation issues, including who defines “appropriate” treatment and who determines whether all options have been exhausted. These decisions require clinical expertise and judgement and should not rest solely with non-clinical NDIA delegates. An independent clinical advisory mechanism is recommended to support consistent and safe decision-making.

For participants diagnosed with ASD, including those with auditory processing differences, audiology supports such as hearing assessment, auditory processing intervention and communication strategies often rely on clinical expertise and individualised approaches. This reflects the heterogeneity of neurodivergent populations and a comparatively limited and variable high-level evidence base in some areas of practice. Strict evidentiary thresholds risk unintended exclusion of clinically appropriate and necessary supports.

AUDIOLOGY AUSTRALIA

P: 03 9940 3900 | E: info@audiology.asn.au W: www.audiology.asn.au

O audiology australia

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Audiology Australia Submission:

Reduction in Funding

The proposed power to reduce funding across categories of support is particularly concerning for people with hearing loss and communication disability. Audiology services, communication supports, and hearing technology are not optional extras- they are essential supports that enable participation in education, employment, healthcare, and community life. Allowing funding to be reduced below what has been assessed as reasonable and necessary undermines the principle of individualised support and risks leaving participants without the services they require to communicate effectively and safely. The proposed safeguard requiring the Minister to consider participant safety is insufficient, particularly if safety is interpreted narrowly as protection from immediate harm rather than the broader risks of social isolation, reduced independence, communication breakdowns, and exclusion from everyday activities. Any future funding reductions should be subject to transparent impact assessment, independent oversight, and review mechanisms to ensure participants with hearing loss are not disproportionately disadvantaged.

Eligibility based on access to other services

This change risks limiting access to the NDIS for people with hearing loss who may also be eligible for other systems such as state-based industrial hearing loss schemes, the Department of Veterans’ Affairs (DVA) programs, or the Hearing Services Program (HSP). While reducing duplication across schemes is important, a blanket exclusion approach is not appropriate where alternative systems provide different, time-limited, or partial supports that may not meet a person’s full ongoing needs.4 There is also limited clarity regarding what would constitute a “declared alternative support” across these schemes, or how differences in scope, duration and funding levels would be assessed. In the context of hearing loss, these programs often provide specific or capped services that do not fully address broader functional and participation needs.5 Any policy settings in this area should be developed collaboratively across jurisdictions and ensure that access to appropriate supports is not inadvertently reduced. Consideration should also be given to how different funding systems can complement rather than exclude one another to ensure continuity of support.

AUDIOLOGY AUSTRALIA SUBMISSION:

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

requirements may place disproportionate administrative burden on audiology providers, particularly small practices and regional services. Given existing workforce pressures and limited access in rural and remote areas, compliance settings must remain proportionate to risk and include clear transition support. Regulatory reform should avoid unintended reductions in service availability or timely access to audiology care for participants

SCHEDULE 3 — GOVERNANCE ARRANGEMENTS

Ministerial decision making

Audiology Australia notes the proposed transfer of pricing decisions to the Commonwealth Minister. Audiology services involve specialised workforce requirements, technology costs, travel requirements and increasing demands for functional evidence and reporting. Pricing processes should remain transparent, evidence-based and informed by ongoing consultation with allied health professions.

Recommendation 4:

Audiology Australia recommends that reform implementation be proportionate, transparent and informed by allied health expertise, with adequate transition periods, clear guidance and meaningful consultation.

Automation of administrative action

We also note proposals relating to automation of administrative action. While automation may improve administrative efficiency, hearing-related disability and communication participation impacts are highly contextual and environment-dependent and may not be adequately captured by automated systems or point-in-time assessments.

Increasing reliance on artificial intelligence for automation may further exacerbate these challenges. Without appropriate safeguards, transparency and human oversight, such approaches risk embedding systemic bias and may result in inequitable or discriminatory outcomes. This raises significant concerns regarding compliance with Australia’s obligations under human rights frameworks, including the right to equality and non-discrimination, and the right to effective participation in decision-making processes affecting one’s life.

AUDIOLOGY AUSTRALIA

P: 03 9940 3900 | E: info@audiology.asn.au W: www.audiology.asn.au

O audiology australia

AUDIOLOGY AUSTRALIA SUBMISSION:

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Recommendation 5:

Audiology Australia recommends that automated systems include strong human oversight, accessible review pathways and access to specialist clinical input where required.

SCHEDULE 4 — NEW FRAMEWORK PLANNING

Audiology Australia is concerned that highly standardised support needs assessments may disadvantage participants with hearing-related disability if assessment methodologies do not adequately account for communication participation and environmental impacts.

Existing Commonwealth hearing frameworks already recognise that some individuals with hearing loss require specialist services due to severe communication impairment, cochlear implantation, dual sensory disability or cognitive complexity.

Recommendation 6:

Audiology Australia recommends that support needs assessment frameworks incorporate hearing-specific expertise, communication participation measures and training regarding hearing-related disability and communication barriers.

CONCLUSION

Audiology Australia supports efforts to strengthen the sustainability, integrity and consistency of the NDIS. However, the proposed reforms risk unintended impacts for people with hearing loss if implemented without appropriate safeguards.

Audiology Australia therefore urges careful consideration of how the reforms interact with these ongoing needs to ensure participants are not disadvantaged.

AUDIOLOGY AUSTRALIA

P: 03 9940 3900 | E: info@audiology.asn.au W: www.audiology.asn.au

O audiology australia

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Selected References

National Disability Insurance Scheme [NDIS]. (2026). NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 – fact sheet. Department of Health, Disability and Ageing. https://www.health.gov.au/sites/default/files/2026-05/ndis-amendment-securing-the- ndis-for-future-generations-bill-2026—fact-sheet.pdf

NDIS. (2026). Provider FAQs: Hearing Supports. Department of Health, Disability and Ageing. https://www.ndis.gov.au/media/2833/download

NDIS. (2025). Mainstream and community supports. Department of Health, Disability and Ageing. https://www.ndis.gov.au/media/7826/download?attachment

Hearing Services Program [HSP]. (2026). About the program. Department of Health, Disability and Ageing. https://www.health.gov.au/our-work/hearing-services-program/about?language=en

World Health Organization [WHO]. (2021). World Report on Hearing. https://www.who.int/publications/i/item/9789240020481

Australian Institute of Health and Welfare [AIHW]. (2025). Ear and hearing health of Aboriginal and Torres Strait Islander people 2025. https://www.aihw.gov.au/reports/indigenous-australians/ear-hearing-health-indigenous- 2025/contents/ear-hearing-health-in-australia/ear-and-hearing-health-services

Cited References

  1. Shojaei, E., Jafari, Z. and Gholami, M. (2016). Effect of Early Intervention on Language Development in Hearing-Impaired Children. Iranian Journal of Otorhinolaryngology, 28(84), p.13. Available at: https://pmc.ncbi.nlm.nih.gov/articles/PMC4735612/

  2. Ching, T.Y.C., Dillon, H., Button, L., Seeto, M., Van Buynder, P., Marnane, V., Cupples, L. and Leigh, G. (2017). Age at intervention for permanent hearing loss and 5-year language outcomes. Pediatrics, 140(3), p.e20164274. doi:https://doi.org/10.1542/peds.2016-4274.

  3. Department of Health (2020). Contracted Service Provider Notice National Disability Insurance Scheme Transition Arrangements - Updated. Hearing Services Program. Available at: https://hearingservices.gov.au/wps/wcm/connect/hso/ee1868dd- 15b6-422d-874c-f2a740fdd612/CSPN+2020-07+-+NDIS+transition+Updated+ -Jul2020.pdf?MOD=AJPERES.

Audiology Australia Submission:

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

References

4.

Safe Work Australia. (2023). Comparison of Workers’ Compensatioin Arrangements in Australia and New Zealand (29th ed., p. 141) [Review of Comparison of Workers’ Compensation Arrangements in Australia and New Zealand] https://www.safeworkaustralia.gov.au/book/comparison-wc-arrangements-29ed

5.

WorkSafe Victoria. (2025). Hearing Services and Devices Policy [Review of Hearing Services and Devices Policy]. WorkSafe Victoria. hhtps://www.worksafe.vic.gov.au/hearing-services-and-devices-policy

                                   AUDIOLOGY AUSTRALIA
                                                  P: 03 9940 3900 | E: info@audiology.asn.au
                                    W: www.audiology.asn.au