Committee Secretary
Community Affairs Legislation Committee
Department of the Senate
PO Box 6100
Parliament House
CANBERRA ACT 2600
AUSTRALIA
01/06/2026
Submission regarding the National Disability Insurance Scheme Amendment (Securing
the NDIS for Future Generations) Bill 2026.
My name is Lindsay and I have been an NDIS participant since 2016. I am also a parent of 3 children, two of whom are participants, with one joining the scheme in 2018 and the other in
- I self-manage all plans and in 2023 supported my eldest child to take over self- management of their own plan.
I am also a Registered Plan Management Provider, operating as a sole trader since 2019. Today I support 127 participants to manage their NDIS funding and provide support to an additional 18 participants and their families as an unregistered Support Coordinator.
While I have a significant number of concerns about the proposed changes in this legislation, I am choosing to focus on two. Firstly, changes to eligibility and a switch of focus from diagnosis to functional impairment, and secondly, the creation of a Plan Management Panel of providers.
About Me
I was granted access to the NDIS in 2016, following my diagnosis of Psoriatic Arthritis in
- This is an auto-immune disease that causes fluctuating symptoms that affected primarily my hands, feet, and ankles. In 2020, I was able to have two additional diagnoses added, Degenerative Disc Disease (affecting my lumbar and cervical spine primarily) and Fibromyalgia. The combination of these conditions causes widespread chronic pain, reduced dexterity and gross motor skills, reduced mobility and strength in all joints, and at times the inability to walk unaided, or transition from sitting/laying to standing without assistance. According to the NDIS, my funded disabilities are “Arthritis – Other” and “Physical – Other”.
I first began having pain and mobility issues in 2005. Since 2007 I have had 6 rounds of steroid injections into my lumbar spine, cervical spine, both shoulders and both wrists. In 2016, I had Facet Joint Radiofrequency Ablation to three level in my lumbar spine, which was done over three sessions, each requiring twilight sedations. This is the burning away of the nerve endings around the facet joints in my spine to reduce pain and assist in increasing mobility and range of movement. In 2020 I had spinal surgery, again on my lumbar spine, to remove part of a herniated disc and small sections of bone near the compromised section of my spinal cord. I currently take 13 prescription medications, including two that supress my immune system making me vulnerable to infections and illness.
Since surgery in 2020, I have found a routine of physiotherapy every 3 weeks (on average) and twice weekly semi-private Pilates sessions have enabled me to build strength and improve my mobility so that I am mostly able to manage my personal care on my own. This means that 80-90% of the time I can shower and wash my own hair, get myself dry and dressed, get in and out of bed (with the assistance of my adjustable bed and fixed handle for leverage), drive myself for 10-30 minutes at a time, get myself to most of my medical appointments, and prepare my own breakfast.
On the surface, I look healthy and well. I can walk myself around and care for my children. I can run my business from home, be a wife, a friend, a daughter, a sister. Underneath though, I haven’t been able to sleep through the night in 16 years due to pain. I haven’t been able to go grocery shopping alone in over a decade. I cannot prepare and cook a meal on my own without causing a sudden flare in my symptoms. I cannot walk outside on uneven ground for more than 30 minutes. I cannot run. I cannot ride a pushbike. I cannot ride on a bus (my only option for public transport where I live). I genuinely do not remember what it feels like to feel rested, or pain free. I have spent almost 21 years learning how to hide how difficult I find most things because I don’t have a choice but to do them. I get accusatory looks from people whenever I park in a disability parking space because I need to open my door all the way to get out. I get told that it can’t be that bad if my disabilities can’t be seen. But as my favourite sticker on my laptop says, “This may surprise you, but most of my body is on the inside – where you can’t see it”.
Diagnosis vs Functional Impairment – My concerns My concern about focussing only on functional impairment is that it will actually mean the assessors interpretation of how they perceive me to be impaired. And those are not the same. All it takes is a misunderstanding of how my disabilities fluctuate, or how I need to allocate my energy every day and adjust my work and my social life to fit around the non negotiable parts of my life. 21 years of getting slowly worse, while also having periods of being so much better cannot be captured if the focus is only on functional impairment, because what that term means for me varies so greatly day to day, week to week, that even I have trouble quantifying it. But when described in combination with my diagnoses, it is easier to understand. I have two degenerative physical conditions, and one chronic systemic condition. Between them, I will get worse over time, and I could not maintain my current level of functional capacity without the NDIS supports I currently have in place. But, if my current functional capacity is all that is focussed on, then I would likely no longer be eligible for NDIS. Until I decline again and lose my business and ability to contribute financially to my family and society, my ability to leave my home, my ability to parent and care for my high needs children. Would I become eligible for NDIS again then?
Diagnosis vs Functional Impairment – Suggested solution No two people with disabilities are the same, even if they have the same diagnosis. Similarly, diagnosis doesn’t always equal disability, and functional impairment does not always indicate disability. The approach to identifying eligibility needs to be as diverse as the people it aims to support. There is no reason that both diagnosis and functional impairment cannot be considered together to assess eligibility for access to the scheme. However, when considering functional impairment for current participants undergoing eligibility reassessments, functional impairment needs to be refocussed on maintaining the reduction
of any impairment. This includes acknowledging that some gains cannot be maintained without ongoing support, and that many disabilities are not stable, but that doesn’t mean that the disability is not permanent. There is absolutely no way that a single approach will meet the needs of very participant or potential participant. Multiple ways to determine eligibility are required, but importantly, they will not all be able to be done within the NDIA alone. The agency needs to be able to acknowledge that they are not the experts on disabilities, and nor should they try to be. The individual and their medical and NDIS support teams are – trust them.
Plan Management Provider Panel – My concerns
I am extremely uncomfortable and angry about the government’s position on plan management and the broader messaging around fraud within the sector. Plan management is already one of the most highly scrutinized parts of the scheme.
We operate under NDIS Commission registration requirements, auditing obligations, compliance standards, financial accountability frameworks, and direct NDIA oversight. Currently, there are approximately 1,440 registered plan managers nationally supporting more than 460,000 participants across Australia who have plan managed supports in their NDIS plan. The broader NDIS market consists of more than 260,000 active service providers. In that context, registered plan managers already represent a very small but highly regulated subset of the overall disability workforce.
Of even more concern, the direction of these reforms appear to be moving towards consolidation of plan management into a small number of very large multinational or corporate providers. From an NDIS perspective, I believe that this risks fundamentally undermining participant choice and control, one of the core principles the scheme was built upon. Confusingly, the current narrative is that it is unregistered providers that are more likely to be “dodgy” and “rorters”, so therefore registered providers are safer – except for this one group (who’s role no-one in the Ministers office seems to understand), and unregistered providers are the whole problem, again except for this one group of registered providers, who’s role has been included in legislation since the beginning of the scheme.
From my experience in the sector, many smaller community-based plan managers (like my business) provide highly individualised support to their participants, spending more time supporting them to understand local services, assist participants to navigate increasingly complex systems, and can identify emerging safeguarding concerns early in ways that large centralised providers simply cannot replicate at scale. Small plan managers are just as capable of meeting the compliance requirements and practise standards as the largest plan managers. This is evidenced by the mere fact they were approved for registration in the first place. There is absolutely no evidence that once registered, plan managers are more likely to commit fraud, collude with other providers, or act with dishonesty than any other type of registered provider.
Another critical issue within the proposed reforms is the ongoing public narrative being presented about the role of plan managers. This includes statements made by the NDIS minister which do not accurately reflect either the legislation or the operational realities of plan management. There have been repeated suggestions that plan managers are driving
unnecessary plan reassessments or financially benefiting from early plan reviews. However, plan managers cannot and have never been able to request a plan review on behalf of a participant under the legislation. New plans and early plan reviews actually create more work for plan managers, including a significant administrative burden, manual processing of claims from the previous plan, increased participant and provider communication, compliance monitoring, and financial risk for plan managers without any additional payment being received.
Plan Management Provider Panel – Suggested Solution
Having reviewed the Explanatory Memorandum for the proposed legislation regarding section 73EA, many small businesses like mine already meet the requirements of the proposed deed of arrangement. I would like to see that any currently registered plan management provider who can show they are able to meet the requirements and are able to show that they will be able to continue to meet the requirements of the deed or arrangement should be able to be added the panel. This will ensure that participants continue to have choice and control over the providers they want to engage and will align with the original intent of the scheme – individualised supports and participant choice and control.
Final Thoughts
While I wholeheartedly believe that reform is required for ongoing sustainability of the scheme, I cannot help but notice that every reform activity so far has failed to look at any internal inefficiency of the NDIA, or that the workforce of external representatives, (like Local Area Coordinators or Partners in the Community) and a lack of training on the legislation and inexperienced staff making decisions about whether a support is related to a participants disability or not, could be contributing to the continued increased spending in the scheme. I am curious as to why the NDIA does not have to meet the same level of accountability and scrutiny that participants and providers do.