Submission 3231 — Name Withheld — NDIS Future Generations Bill

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Subject: Concerns Regarding Proposed Changes to the NDIS

Attention: Committee Secretary, Senate Standing Committee on Community AƯairs

Submitted by email: community.aƯairs.sen@aph.gov.au

Date: 1st June 2026

I welcome the opportunity to make a submission to the Senate Standing Committee on

Community AƯairs about the National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

I am writing to you as a concerned Australian with a strong interest in the future of the National Disability Insurance Scheme (NDIS), and the wellbeing of the people who rely on it every day. I personally am a smaller individual focused Plan Manager who also has lived family experience of the complexities of living with a disability.

The NDIS has been one of the most transformative social reforms in our country’s history. However, I am deeply concerned about several proposed and emerging changes that may undermine its core purpose — to support Australians with disability to live independent, dignified, and meaningful lives.

This bill is being rushed without proper considerations and knowledge being utilised to ensure the best outcome is obtained.

The recent announcement of changes I believe show a lack of understanding of the industry and roles and responsibilities of providers and participants. As such I want to provide further information and propose solutions to the many issues present within the NDIS as I completely agree that the current situation is unsustainable and needs reform.

Proposed Changes

  1. Moving from Diagnosis-based eligibility to Functional Assessment This is a big step in the right direction and should have been implemented from the start. Every participant once they are accepted as eligible for the NDIS should undergo a formal functional capacity assessment in which plan funding is generated based oƯ. To go one step further and have assessments standardised have the assessment done internal of the NDIS by qualified professionals or provide licensing to set therapists that ensures a standard approach and will stop participants “doctor/therapist shopping” to get the report they want. However the big concern with the move to change the definition of permanency is completely wrong. My partner who suƯers from uncontrolled epilepsy has been refused access to the NDIS due to the fact she has not tried all available treatments. The NDIS has said until she has had invasive Vagal nerve surgery she hasn’t exhausted all available treatments. The issue is her treating

epileptologist, neurologist and specialist teams have repeatedly stated that this treatment will not work on her type of epilepsy and carries far greater risks than would be worth attempting the surgery and as such would NOT do it. Currently she cannot access the NDIS due to this already being an issue. A group of uninformed, non medically experienced bureaucrats make this determination as opposed to the reporting given by her treating professionals who have years of medical experience, research and training in this area and intimate knowledge of her specific situation and condition is all disregarded. This is just one of many examples of where the NDIS themselves needs overhaul and changing to have qualified personnel reviewing medical data and therapist reporting. This would solve so many tribunal and subsequent reviews which the NDIS’s own reporting shows they lose something in the realm of 97% of cases taken to the ART and they admitted in recent findings they don’t even bother to read the reporting obtained specific to a participant before handing out a plan, hence why there is constant reviews being lodged clogging the system. This non reading of reports should have staƯ dismissed and management held accountable for wasting of taxpayer funds. This action alone would ease the pressure on the scheme and cut the costs involved.

  1. Reduce the overall participant numbers This is also a good aim, however with the introduction of Thriving kids the number will reduce as many move to this program. It is more of a shuƯle than a solution. The biggest problem in this space is the State based schools funding systems which encourage schools to over report disabilities or GDD etc. to obtain additional funding. This then flows through to them assisting getting kids onto the NDIS as additional supports to make the classroom easier to work for them. It has parents chasing diagnosis’s of ADHD, Autism, GDD etc. for funding when these diagnosis themselves are low accuracy or inconclusive at young ages especially for low to mild ASD levels. This is robbing supports and creating greater wait times for those with higher level of ASD that are genuinely in need of supports. This is where Thriving kids appears to be a good move.

  2. Slowing NDIS spending growth This issue is complex but there are several areas of quick and easy savings –

a. No raise to the current pricing guide maximum prices for the next financial year and going after providers who engage in practices to claim additional funds through report writing etc on top of the hour of therapy provided. This will facilitate providers to make internal savings, be more eƯicient with a greater focus on supporting participants and providing greater value to participants. This price freeze will also have the market remove the poorly run entities from the industry. Many larger run

organisations are cluttered with non-value add layers of management that don’t enhance the participant experience and then spend significant levels of funding on advertising and oƯice locations in prime real estate locations which again isn’t helping provide a better service to participants.

b. A coordinated approach with State Governments around the SCHADS award. Remove the need for any employee to be paid a minimum of 2 hours for engagement for any NDIS provider. This change by Fairwork is completely against how the NDIS model funds participants and creates a disconnect between the two levels. Bring back the flexibility of 1 hour shifts so that participants can access the support as they need and are funded for. At present a participant who needs daily assistance for certain tasks, eg showering has a budget built with funding for that task taking 1 hour of support, however they are left stranded with either having to use extra funding and engage a provider for the 2 hours as the provider wont engage with them for 1 hour of support due to the staƯ costs.

c. Daily supports for common tasks should be done at a group level. This component can be assessed at the initial functional capacity assessment done at point #1. This also incorporates the lowering of social and Community funding being required (further points will be made later). When the initial functional capacity assessment is done as per change #1, a participants disabilities are assessed and classified in certain criteria levels. Eg someone with significant disabilities that limit their physical ability to prepare a meal for them, these people are provided with meals, however there are many participants who need assistance with preparing meals safely as they have some capability of completing this task but not the full ability. These tasks should be done at group level and done by a qualified chef with support levels deemed necessary for a participant. Eg a person with moderate ability would have say a 4:1 participant to support ratio. This would fulfill three levels of personal needs per participant (1. Preparing meals for them for the next 3-4 days, 2. Social interaction with other people, 3. Developing skills around food and food safety). Changing these type of daily supports from being 6hrs per individual participant per week to have these split into two shifts of approximately 3 hours each week at a group level reduces the cost to provide these supports to around one quarter of the amount of the current level plus achieves the additional mentioned outcomes.

d. Participants providing support work to one another. This practice should be banned, if a participant has funding themselves for a support worker they should not be able to provide this same support service to another participant as for them to require said support would mean they are incapable of performing these tasks themselves yet they are supposedly doing this for another participant. However currently many participants are creating NDIS funded lifestyles for each other acting as both the supported person and the support provider. This again could easily be controlled through the provider NDIS number I talk about in the next section 4. (i).

  1. Increased Fraud and Compliance Crackdown This is a big one for me, as a Plan Manager I see this nefarious behaviour from participants and providers from time to time. The single biggest issue in this area is the NDIS themselves. I have reported 3 separate times of major fraud to the department of an organised criminal network targeting vulnerable participants with psychosocial disabilities with large value plans. Yet in the almost 2 year period these providers are still operating, fraudulently obtaining a minimum of $5k per week per participant running a rooming house of 9 participants. That could be around $45k per week they are stealing. Plus they also operate several other rooming houses and are most likely doing these practices at these as well. The NDIS, Quality and Safeguards commission have done absolutely nothing in this time with the three reports and are actually facilitating the fraud by moving the service bookings to another plan manager without even contacting myself who had the service booking and was preventing them from continuing their fraud. The NDIS should have as part of their process to simply contact the current plan manager when there is an active fraud report against the participants plan to see if there is any issues before moving the participant. This can be done whilst still allowing choice and control or at the very least they need to have on their system a check against any possible fraud. Many of these participants should have been taken Agency managed to prevent this action. What makes this case worse is that I have flagged this group of providers for over 2 years and as plan manager not paid any of these invoices to which the “dodgy” providers then collude with the participant oƯering illicit substances, threat of violence or cash payments to move the participant(s) to My Plan Manager (the biggest plan manager in the scheme) who is now paying their invoices. This is where my issue with the preferred providers come into it as the larger plan manager providers are oƯshoring services without adequate training and participants become just a number who they don’t know their regular supports and cannot spot when something is out of the ordinary. On top of this as

mentioned before My Plan Manager as proof in this case doesn’t even do proper checks, the organisations mentioned as “dodgy” providers were claiming invoices via services that where supposedly occurring prior to the company coming into existence in which they didn’t even check the abn’s validity or withhold tax or obtain a supplier statement for said services. The support coordinator had raised this with them to which they didn’t care. This level of incompetence, lack of checking and practice is what makes being a smaller plan manager so frustrating as we work so hard to ensure our participants are supported and following the rules yet the big providers are not complying with basic checks, this incident is not a one oƯ, it is a repeatedly found behaviour by this firm. I am happy to provide specific details further to this case mentioned as the second part of the issue is the lack of action by the NDIS and Quality and Safe guards commission.

The move to have providers registered is completely pointless as many dodgy providers are already registered and/or are involved in the registration process. One can simply buy an already registered business and operate tomorrow with no knowledge of the supports they are providing or the compliance requirements.

i. A simple solution is already available, each person working in the NDIS is given an NDIS number upon completing a NDIS worker screening check/orientation training. This number is unique to them. Change the rules to include every support provider must include the NDIS number of the person providing the support in which the NDIS can then block, remove/ban enquiry further into an individual from providing the support if they break the rules. The NDIS themselves can administer training programmes or have them provided from professional bodies that workers can complete to be deemed competent and compliant in a support category and once this is completed and passed they can provide supports under this category. The NDIS can then conduct randomised audits to ensure compliance. All of this can be done without registration and simple wording changes in the NDIS Act. This database is then matched in the invoice claims to ensure all providers are competent/qualified in the area(s) they are providing support for. It creates a way for the NDIS to directly pursue or work with individuals to ensure compliance and safety for participants. We don’t need the complex, costly, corrupt registration process to turn the NDIS into the failing Aged care system with big providers neglecting/failing the

customers they are supposed to be helping.

  1. Changes to Plan Management and Funding Controls The constant rhetoric by the minister of plan managers being ticket clippers, getting plans reviewed to get further funding for themselves and committing fraud is abhorrently wrong. Plan managers are paid a set fee per month so no plan review increases the funding they get. This is a clear lack of knowledge of the system as the minister has confused plan managers with Support coordinators. The change proposed by Mr Butler to have a preferred provider list needs to have more details provided - Who is the preferred providers list (what is the criteria for being on this list)? If this list is intended to be made of the large entities in the space who have “purchased” a seat at the table to negotiate with the Minister and disregard the smaller providers who provide a more customer focussed approach it will not help the integrity of the scheme. These large providers are part of the problem in the scheme, being owned by either foreign entities or large Health insurance funds who have little regard for the end participant, staƯ and regulations simply seek to maximise profit. These entities themselves create many problems faced in the system in that they oƯ-shore services and use foreign workers to maximise their profits and as such facilitate fraud with lack of compliance as mentioned in my prior fraud case and other examples of dodgy providers and participants moving to them so they can have less scrutiny put on their nefarious practices. This above mentioned fraud case is only one of several I have reported over my career working as a Plan Manager, in which far better action needs to be taken by the Agency in dealing with reported fraud. Keeping participants with smaller more personalised providers will help with compliance and mitigate fraud plus provide personal specific supports was the very reason the NDIS was introduced and why many participant have chosen to go with smaller providers.

  2. Further Possible Solutions to consider Instead of moving the scheme to a larger centralised system with less controls and less personalised supports what needs to be considered is the Plan Manager role expanding and merging to include Support Coordination function and be more of an all inclusive case manager. This would provide significant improvements in the integrity and functioning as an individual plan manager would

a. look after a smaller number of participants,

b. know the participants extremely well and their specific disabilities, making the support more personalised,

c. be local to the area the participants are living, in order to best support them with local providers.

d. oƯer the ability of being able to negotiate better rates with providers e. prevent exploitation of participants by bad providers f. give greater transparency and auditability of supports provided and invoiced claims.

This proposed model would create additional changes within the NDIS which would create additional cost savings. The removal of many back oƯice staƯ who do not add to the integrity of the scheme, who do not have the knowledge/training of the NDIS rules/regulations or ability to directly advise on a participants circumstances. Namely the Local Area Coordinators and Partners in the Community System which has failed to deliver in its role as staƯ are on short term contracts resulting in high staƯ turnover preventing them from having the adequate knowledge and also the capabilities to provide meaningful supports to participants. This would result in about 6000-8000 jobs removed and a cost saving of $1.5-$2 billion annually. The newly proposed Navigators role would be scraped also as this whole function would be performed be performed by the new version of a plan manager. Secondly their wouldn’t be the need for such an extensive call centre staƯ who again are not trained well enough or don’t have the capability to provide specific answers to participant and provider needs.

These roles would all be covered oƯ by a single point of contact namely the Planner. The Planner being the person who formulated the participants plan and person who has the ability to directly advise specifically to the individual participants circumstance. This increase in direct contact may lead to a slight increase in the number of Planners required to service the needs, however it will deliver a greater outcome for the participants needs and ensure compliance of the rules and the meaning of “reasonable and necessary” is determined with the best available knowledge of the system and participant. The Planner also serves as a check point in the system in which the participant can go to if they have any concerns around the plan manager and how they are operating. With these changes several safeguards should be put in place to protect both the participants and the NDIS integrity.

I. Whilst having a single point of contact and person responsible for a participant (being the Plan Manager) provides for a better service it also

could have a scenario that the participant is not serviced properly by a poor Plan management provider. As such the NDIS Planner becomes the point of contact if the participant has any concerns. II. Plan Managers are made up of businesses with a minimum of 2 staƯ and a maximum of 10 staƯ. This ensures there is continuity of support for all participants in case staƯ go on leave, but doesn’t allow a business to become too large that a participant won’t directly know their Plan Manager and is at risk of becoming just another number as the business puts funding to non value add activities in order to grow (eg levels of management and advertising) III. The number of participants a single plan manager staƯ could look after would need to be capped at a maximum of say 40-50 hours per week to ensure at no point a participant is unsupported by a plan manager who is over-stretching their abilities.

The fees a plan manager would charge would be based on the complexity of each participant. The original assessment done at Point 1 would classify each participant according to the assistance they need, this would then create a weekly/monthly amount a plan manager would be compensated for. So for example all participants should be having a check in at a minimum monthly with the plan manager this would be for the low level support needs where a participant is capable of independently arranging and actioning their supports. This participant would have say a 15-30 minute check in each month plus ad-hoc queries along with all there invoices claimed and paid, this may attract a fee of say $250 per month. As opposed to a participant who needs a weekly check in and scheduling of supports would attract a fee of say $250 per week, $1000 per month. Those with extremely high levels of support requirements eg daily coordination would have specialist support coordinators dedicated to their needs, these coordinators are trained mental health and specialist qualified providers. A Plan manager would then be paid the base rate of $104.45 to process the invoices and manage budgets and compliance as currently happens. This more overarching role will provide –

g. the ability of a central point to negotiate a better deal/rate on behalf of the participants they work with. Eg if multiple participants need Community access supports they can coordinate a group session or a group therapy deal with a provider. All whilst still maintaining a participant ability to exercise choice and control over who they ultimately choose as a provider.

h. This would protect participants from being exploited by bad providers as there is a close monitoring of supports and a single point of contact for the participant to get assistance from and supports claimed and paid by.

i. The plan manager would be still a qualified accountant and have a far greater knowledge of the compliance and NDIS legislation/rules, making them well situated to keep records and understand legislation, in a similar manner to what occurs in the taxation model.

j. The Planner and plan manager have a closer working relationship in which specific participant circumstances or issues can be discussed and resolved quickly making a better experience for all.

I could continue to go into further measures and changes that need to occur to improve the system however at the very least greater accountability needs to be enforced and actioned within the NDIS itself rather than the constant grandstanding by ill-informed politicians. The information provided in points 1 to 5 provide a great scope to start with and should be included in considerations of improving the system as it currently lies.

I thank you for the time taken to read this and hope it contributes to make the scheme better for all.

Sincerely