Submission 3170 — Name Withheld (Attachment 2) — NDIS Future Generations Bill

National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

IMPORTANT CONSIDERATIONS IN DEPTH

in response to announcements by Minister Mark Butler on 22 April 2026

This is the companion document to the summary: CALCSubmissionPart2_Summary_20260601.pdf

This is not an exhaustive list of concerns.

Prepared by NDIS Participant, Parent of a person with disability, Former Disability Support Worker, Former Young Carer.

1. Anyone anywhere of any age at any time could acquire disability. The NDIS is for every Australian.

2. People with disabilities want the NDIS to be sustainable and succeed more than anyone. Our lives depend on it! Our lives depend on YOU to represent us effectively.

3. Every $1.00 invested in NDIS Participants returns $2.25 to the economy. It is not welfare. It is productivity, human rights, an investment in our lives and Australia’s future prosperity

4. People with disabilities are their own best experts on their disabilities and their own lives. This expertise based on lived experience must be respected and taken on board by decision-makers.

5. Decisions have real world consequences beyond the person with disability.

6. People with disability are being punished and scapegoated for government and NDIA shortcomings. People with disabilities should not be bearing the brunt of NDIA’s lack of due diligence.

7. People with disabilities demand the NDIA get its ‘own house in order’ before blaming Participants and Providers for cost blowouts. Less lawyers, more lives lived with dignity.

a. Why did the NDIA spend around 60 billion dollars on lawyers fighting Participants about things that are necessary, reasonable and a tiny fraction of the legal costs to put in place? These are things that give us independence, choice and control according to the Scheme’s vision. When the majority of disputes are ruled in favour of the Participant, how is that ‘value for money’?

b. Re: Schedule 1 Part 4 Support Determinations; Part 6 Reasonable and Necessary Supports The NDIA makes fiscal decisions that ignore its own requirement for spending to be ‘value for money’. For example: The NDIA does not recognise that ‘mainstream’ appliances can be essential ‘AT’. The NDIA would rather spend tens of thousands of dollars more on Support

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Workers (over $11,553.61) instead of providing a Replacement Support AT which is a fraction of the cost (approximately $2,298.00) and will last 20 years, while increasing independence and choice and control. This doesn’t pass the pub test.

c. The Minister for Health and Ageing, Disability and the National Disability Insurance Scheme gave an example of the NDIA’s shortcomings, “The Agency committed to getting those reassessments down from 20 per cent a year to 15 per cent but hasn’t been able to deliver on that.” Then proceeded to blame Plan Managers for the NDIA’s problem. We need accountability, not blame, to solve problems.

d. Nothing gets spent from my NDIS Plan without approval from the NDIA. . 8. Re: Amendment Schedule 1 Part 2: Limit Unscheduled Plan Reassessments If the NDIA Planners and Delegates understood disability more and didn’t have their decisions clouded by internalised and normalised ableism, perhaps more Plans would be produced that accurately met people’s needs and there wouldn’t be the need for so many costly unscheduled plan reassessments and reviews!

a. No Participant or Nominee wants to go through stressful bureaucratic processes if they don’t need to but people are desperate. People are dying. It’s our very lives they are playing with.

b. The Minister for Health and Ageing, Disability and the National Disability Insurance Scheme described unscheduled reassessment of NDIS Plans as a “huge driver in spending growth” and “Most significantly [sic] in spending blowout terms.”

c. We know that NDIS Planners and Delegates carry ableism with them when they arrive at a person’s home and inappropriately ask a Participant, “So, what’s wrong with you?” which does not reflect the values of the Social Model of Disability upon which the NDIS was designed; a concept in alignment with the UNCRPD.

d. We know the Minister doesn’t understand invisible disability when he uses the terms ‘mental health’ and ‘psychosocial disability’ interchangeably during his speech.

9. I feel like my life is as a disabled person is being used as a political football in public debate and by politicians. I am not the only one and this is causing harm in our communities.

a. Who else has every tiny aspect of their lives scrutinised and judged in the way disabled people do? Right down to when or whether you can go to the toilet or have a shower or even leave your home.

b. It is harmful and distressing to be viewed as less than human – a data point, a budget burden. CALCSubmissionPart3_InDepth_20260507_12pp.docx Page 2 of 12

c. A neighbour likened the public debate around the NDIS to that of the time of the gay marriage plebiscite which caused harm from which some people have never fully recovered.

d. The government has created a narrative where NDIS Participants are now targets of community resentment and mistrust during a cost-of-living crisis.

e. We are having our disabilities questioned and our identities, our very humanity, attacked. The Jewish communities in Europe were also used as scapegoats during the time of Nazi Germany and the economic depression of the 1930s. People with disabilities see the similarities in current community behaviour and public discourse.

f. The government narratives around disability and the NDIS are creating social division and unrest, not cohesion. This is very irresponsible from people who are placed in leadership positions to serve their constituents.

g. Government narratives demonising disabled people has opened the floodgates for ableism to become visible and vocal so that we cannot feel safe in our communities. “Having the NDIS so sharply in focus in the news cycle has brought out all the ableist public comment. Society doesn’t feel so safe any more.” This is happening in Boothby RIGHT NOW

h. Misinformed ableist attitudinal barriers will hinder any notions of “Inclusive Communities”. i. Treasurer Chalmers’ ableism is showing when he perceives people with disabilities as easy targets for easy savings.

j. Is it truly the ‘social licence’ of the NDIS that is being lost or the ‘social licence’ for cruel government decisions?

10. The message from government: “If we don’t fix the NDIS now, we’ll lose it forever,” feels like an ultimatum, as if our lives as people with disabilities are being held hostage to the nation.

a. If Ministers and legislators were held hostage for ransom, what monetary value would be put on their lives? I ask this as I consider the way the NDIS quantifies our worth as humans living with a disability, converting the worth of our human lives to dollar amounts, in the way support funding is allocated, both from within the NDIS and Australian Government budgets.

b. The way the NDIA is already denying basic human rights to NDIS Participants with arbitrary cuts to NDIS Plans, without consideration of individual circumstances, is an indicator on how little the lives of ordinary Australians with disabilities and their carers are worth to decision-makers.

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c. What happens if the current decision-makers find themselves needing support – whether from ageing or perhaps compounded by acquired disability – will there be any compassion left for them or will society have turned cold after following successive governments’ current leads of harmful narratives and cruel policies? Where is the humanity?

d. Will these people be willing to ‘die for the cause’ when their perceived economic usefulness is over? Recent government policies send the signal that Australians are only useful if we can earn enough to be taxpayers and that people with disabilities and elderly are not taxpayers and are only worthy of the scrapheap. People with disabilities and older Australians do pay tax and contribute to our economy

e. Whether it’s in the shops or to our support providers, GST paid by people with disabilities goes straight back to government! Maybe the GST from the disability sector can be targeted towards Foundational Supports?

11. The co-opting by politicians of the disability rights movement’s catchphrase, “Nothing About Us Without Us” is offensive when there has been no true or meaningful co-design with people with disabilities.

a. The Minister for Health and Ageing, Disability and the National Disability Insurance Scheme did not consult with States or representative organisations for people with disabilities before making announcements at the National Press Club on 22 April 2026.

b. It is hypocritical of the Minister for Health, Ageing, Disability and the NDIS to have an office that is physically inaccessible and hostile to constituents with disabilities. No excuses. Someone made a decision to choose that building for his office and that speaks volumes.

12. Re: Amendment Schedule 1 Part 4 Support Determinations I am scared of what’s coming for the NDIS: ‘black box’ algorithms, no rights of appeal, no human intervention or discretion around funding decisions and processes.

a. We are seeing this play out in the Aged Care system right now with cruel and disastrous results.

b. Adverse effects in Aged Care through the use of ‘black box’ algorithms to calculate aged care packages that are grossly inadequate and inhumane. The Government has signalled it wants to do the same to people with disabilities with expectations by the Prime Minister of automated decision-making processes being used across ALL areas of government. RoboPlans = guaranteed RoboDebtDeaths.

13. Re: Amendment Schedule 1 Part 4 Support Determinations; Part 9 Eligibility based on access to other services

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I am scared because Minister Mark Butler said, “… this will see us rebuild systems that used to be there for people with less significant support needs.” The ‘old systems’ FAILED.

a. The ‘old system’ was not-fit-for-purpose, did not cater for the needs of younger people (under 65) with disability, was underfunded, inappropriate, inadequate and unsafe. I do not want to go back there.

b. We need to build new systems from scratch with earnest co-design from government together with the disability community, and maintain the human rights values of individualised support.

c. In the old system, I fell through the gaps along with many others. This is why the Federal Government had no idea how many people live with disability in Australia and underestimated the demand on the NDIS.

d. When I finally gained access to the old State system after years of access barriers, I was only allowed support for 2 showers a week and was allocated half an hour per shower. I could not choose when I showered or who showered me. It was inadequate, unhealthy, undignified and unsafe.

e. I had no choice and control about grocery shopping – when I could go, where I could go and how much I could purchase were restricted and caused hardship. The rules around shopping support were created for older people who lived alone or in couples. I was a single parent with three children, one of whom is on the autism spectrum, in a busy household.

f. Workers were trained for Aged Care and not Disability Care or working with children. There were inappropriate behaviours and expectations from workers towards myself and my children who were also ‘Young Carers’.

g. I fell through the cracks of the state system prior to the NDIS. I ended up bedridden and frail, isolated in my home, unable to raise my voice to be heard across the room. I was frequently in and out of hospital.

h. The old system waived fees for people on low incomes and in financial hardship until the state privatised it. Co-payments were demanded from the business that was contracted which made support unaffordable and inaccessible for me. I was then without supports until accepted into the NDIS.

i. Relatively modest charges of $10/hour/item were unaffordable for us so we just went without and went backwards functionally. Will Foundational Supports look like co-payments?

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j. The state government used contractors to supply services. There was no choice and control for recipients and no provision to change provider in the event of problems with that provider. People were forced to choose between unsafe people in their home or foregoing services.

14. Re: Amendment Schedule 2 Part 6 Registered Plan Management Providers The NDIS was created because the fragmented, underfunded, not-fit-for-purpose, block funded state systems were not working and causing harm to people with disabilities. We cannot go backwards.

a. History shows us that block-funding models are not safe for people with disabilities. b. Organisations used a ‘block-funding’ model of an arbitrary dollar amount per person which did not take into account that some people had more complex needs than others.

c. It was in organisations’ interests to attract as many clients as possible to get enough funding to pay salaries first, care for people second. This is not a client-focussed model.

d. There were scandals about agencies being funded to support people with disabilities and their families when board members were driving around in fancy cars with opulent lifestyles while people with disabilities and families struggled with unmet need.

e. Often the arbitrary funding amount allocated per capita was inadequate for someone with complex needs or who found themselves in crisis. The only way the support providers could support that person was to ‘borrow’ or ‘re-appropriate’ funds allocated to other clients from within the block of funds.

f. Subsequently other clients, despite carefully managing their own spending according to an allocated budget from block funds, ended up with inadequate funding to meet their needs and were also pushed into crisis, creating a culture of harm and neglect.

g. Running a support business management model based on ‘fighting forest fires’ and crisis management is not sustainable for the people involved as well as financially.

h. This history is why many people with disabilities are fleeing large ‘legacy’ disability providers for newer, smaller, more agile disability-led providers and independent support workers who support the social model of disability in alignment with the UNCRPD.

i. The NDIS was created to solve unmet need and people falling through the gaps; to increase productivity and participation instead of complete welfare dependence and poverty.

j. Fear of going back to a failed state system is deep. I truly believe the NDIS saved my life and to take that away becomes an existential threat.

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k. Quote from NDIS Participant: “The reason why there’s so many unregistered providers is so many NDIS participants have battle scars from the bad old block funded sector that are now largely the registered provider sector. We’ve suffered so much abuse, neglect, and Kafkaesque red tape from them that we run away from them screaming.”

15. “Heed to succeed!” Foundational Supports need to be planned very carefully and thoroughly with earnest co-design by government together with people with disabilities in order to succeed.

a. This process cannot be rushed. Value our expertise and heed it. 16. My best workers are not from big business agencies but individuals and smaller local providers including those run by people with disability for people with disability. Big corporate agencies can’t provide the stability and safety my current team provides.

17. Re: Amendment Schedule 2 Part 1 Registration of NDIS Providers I am scared of losing my best Support Worker care team ever if mandatory registration is too onerous or prices independent workers and small-to-medium businesses out of the market. (I fear going back to the old block funded large agencies which perpetrated harm.)

a. I have grave fears for the hollowing out of the disability support ecosystem with these changes.

b. Already we have seen successful businesses started by people with disability and for people with disabilities get pushed out and overtaken by larger corporate entities which are not person-focussed but focussed on the corporate interests to the detriment of the disability community.

c. E.g. When Hireup was started by people with lived experience of disability, it was very client-focussed and gave me ‘choice and control’ over who came into my home and my life to support me. When it was sold to a new owner, it was obvious from communications that the wellbeing of clients and employees came second to their corporate concerns.

d. The ensuing communications and demands of Hireup’s new management, bordering on harassment for both employees and clients, have not been person-focussed. They have been inappropriate and offensive. One of my best workers was unable to continue working with me when they joined a new agency because Hireup was disrespecting them.

e. I nearly lost my other excellent, reliable, Hireup worker for the same reasons. That worker is still supporting me through Hireup but has since found more work elsewhere and is seeking less work as a Support Worker through Hireup.

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f. This upsets me because these workers came into the Support Work role because they like working with people and are well-suited to the role, with professional attitudes and commitment. They were in previous roles like retail and real estate and were looking for more meaningful work that suits their people skills like in the disability support sector.

g. When agencies and systems do not respect the humanity of our support people, people with disabilities end up with workers who are ‘just in it for the money’, take the lead from a callous agency culture, and are disrespectful of the needs of people with disabilities.

18. Re: Amendment Schedule 2 Part 1 Registration of NDIS Providers Mandatory registration of Providers must be ‘light touch’ registration – simple, affordable, without onerous bureaucratic compliance requirements or we will lose highly skilled Support Workers and Allied Health providers from the sector.

a. One of my former allied health providers refused to continue servicing NDIS Participants because of the administerial requirements which prevented core business activities of directly working with clients.

b. I am concerned bureaucratic demands that take too much of small providers’ time away from their core business of working with their clients, will interfere with their ability to financially survive, shrinking tight marketplaces further and reducing choice and control for Participants.

c. Larger Providers that benefit from economies of scale are able to absorb bureaucratic demands better than small Providers.

d. Costly compulsory registration for all providers sets up conditions for smaller providers to be purchased and absorbed by big businesses that can afford the registration demands. In doing so we lose the healthy inclusive non-ableist cultures many new operators provide. Safety and choice disappear.

e. Like the negative economic effects on rural communities when large companies buy smaller farms and a once tight-knit community of multiple farm households turns into one giant operation. Residents leave the town and with dwindling populations, services leave soon after. Valuable infrastructure and capacity are lost.

f. If compulsory registration for all kinds of NDIS service provision is introduced, the market reality coming to the disability ecosystem will be . Less choice and control, less innovation and improvement, poorer quality, less competition and higher prices, poorer outcomes for participants, local business economies and their communities.

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g. I worry about the motives of some people’s lobbying for mandatory registration for all providers, particularly when they have been involved in ‘old systems’ and large ‘legacy’ operations.

h. We need to protect providers and business based on the quality of service they provide by providing conditions for innovative, effective and person-centred models of service provision, as determined by people with disabilities, to thrive.

19. Re: Amendment Schedule 2 Part 1 Registration of NDIS Providers Independent Support Workers and Sole Traders bring great value to the disability care sector.

a. Sole Traders need to give excellent client-focussed service to stay in business. b. They commmit to the role as a career with ongoing professional development and not just a temporary fill-in job or Centrelink participation / mutual obligation requirement.

c. They can be more reliable and provide stability and a secure framework of support for people with disability and their families.

d. These people get head-hunted for their services. We need to keep them in the sector and not push them out.

e. Support Workers who become sole traders often do so because agencies have not respected their needs as employees. They show no wish to return to being employees.

20. Re: Amendment Schedule 2 Part 1 Registration of NDIS Providers Sole traders and small businesses are better placed to provide more effective individualised services than large organisations where humanity gets lost amidst the numbers.

a. Smaller operations have smaller customer-bases – get to know the nuances of clients and employees very well for compatible client-worker matches and safety. Everyone can bring their whole selves to work and have a healthier, more sustainable work and support environment.

b. Sole traders and independent support workers are more willing to negotiate service agreements to meet individual needs, unlike large agencies which offer ultimatums (accept our non-negotiable service agreement or no service).

c. There is scope for more empowerment of people with disabilities. Choice and control. d. There is more scope to build trusted long-term relationships which provide safe continuity of service.

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e. When people with disabilities feel safe with their support people, they are then able to move from ‘surviving’ to ‘thriving’. Safety does not come easily when there is a high turnover of different people coming into and out of our lives..

21. Re: Amendment Schedule 2 Part 1 Registration of NDIS Providers Mandatory Provider Registration in itself is not a safeguard.

a. Anne Marie Smith died at the hands of a Registered Provider b. Aged Care Providers were all seemingly registered and regulated when deaths and harm occurred from abuse and neglect in that sector. Refer to the Royal Commission on Aged Care Final Report.

c. Please refer to quote at 13.k. about the reason for so many unregistered providers and why registration does not automatically mean safety for people with disabilities but the contrary.

d. People with disability and those who have their interests at heart, need to have the power to choose the best people for their individual needs, whether they are registered or not.

22. Re: Amendment Schedule 2 Part 1 Registration of NDIS Providers. Registration means nothing if regulation is weak and cannot be enforced.

a. Registration provides a ‘line-of-sight’ but is anyone watching? Who is watching? b. History shows that registration in all sorts of fields doesn’t necessarily equate with honesty and integrity.

c. Registration can be a disincentive for nefarious people. d. The Quality and Safeguards Commission has been a ‘toothless tiger’ in the eyes of many. 23. Re: Amendment Schedule 2 Part 1 Registration of NDIS Providers; I want the choice to choose providers that are not registered and do not charge an “NDIS tax” (like a “wedding tax”) for the same service that others in the community get cheaper.

a. Providers usually justify “NDIS Tax” as the extra administrative burden required for registration and compliance. At the end of the day, people with disabilities pay more, and it costs the NDIS more.

b. Where are NDIS requirements duplicated in other systems; e.g. allied health professionals already need to be registered with AHPRA? Let’s remove the need for providers to ‘re invent the wheel’.

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c. Wouldn’t the removal of duplication and streamlining of administrative processes also partly relieve the administrative burden on the NDIA itself?

d. I’ve heard small providers say that registration costs between $10,000 and $20,000 per annum. How does a small start-up provider or microbusiness like an independent support worker afford that on support worker wages?

e. There is a dignity of risk in choosing our own providers and a dignity in supporting businesses that provide good service and align with my values, regardless of registration.

24. Re: Amendment Schedule 2 Part 1 Registration of NDIS Providers The idea of curating a prescribed list of Support Providers and intermediaries like Plan Managers and Support Coordinators from which Participants can choose, is taking away our real Choice and Control which is an integral part of the ethos of the NDIS which aligns with the UN Convention on Rights of People with Disability (UNCRPD) to which Australia is signatory.

a. Minister Butler said, “Our government will identify a short list of accountable quality providers which people can then choose from.”

b. Accountable to whom? Actuaries? Safeguards Commissions? Treasury? People with disabilities? Nothing about us without us.

c. It looks like the ‘bad old days’ where disabled people were stuck with the provider chosen for them by faceless bureaucrats, possibly according to criteria that is more important to the bureaucrat than people with disabilities, even if that provider cannot meet individual needs and care recipients are harmed. This is the opposite of Choice and Control.

d. It looks like an opportunity for corruption between government and business – ‘mates’ rates’ and ‘jobs for the boys’.

e. How would the Minister know about all of the providers in the country when considering who to put on his list? Where will his information and advice, if any, come from?

f. What criteria will be used to choose which providers are prescribed? g. I’m concerned that a prescribed list of providers keeps new players out of the market, stifling choice and control.

h. I’m concerned that older, larger Providers who are more able to lobby government and promote themselves than smaller Providers will be the only ones Participants get to choose from. It will be back to the ‘old days’. Please refer to points 14.k., 17.a. and 18.d-f.

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a. There are still plenty of places in Australia that do not have internet services. How does one enforce digital payment systems on providers where internet and phone services are patchy or non-existent?

b. How many culturally competent, safe, effective support services will be locked out of the digital payments system due to lack of infrastructure? How will the government make sure the infrastructure is in place by 2028?

c. If it becomes mandatory for all providers to be connected to a custom digital payment system, how will that work? Will Providers need to purchase extra capital like specific transaction terminal equipment? How will that be equitable for Providers and Participants including self-managed Participants?

d. I am concerned it will be used as another expense barrier for big business to survive while smaller businesses and sole traders get pushed out of the market because they cannot compete financially and people with disability will lose essential trusted stable supports that meet their individual needs to a high standard.

e. If Participants become unable to be self-managed, what kind of administrative burden gets returned to the NDIA? What happens to choice and control and capacity building?

26. Sole Traders and Independent Support Workers deserve the same hourly rate for their services as other larger businesses.

a. They may have fewer capital overheads but have fewer hours available for earning; e.g., one person cannot earn as much as 30 people can earn for a business in the same time.

b. They still need to cover the same compliance costs such as qualifications, certifications, registrations, insurances, vehicles but with less earning capacity and without the economies of scale of big business.

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