National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 3256
Submission to the Senate Standing
Committee on Community Affairs
Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for
Future Generations) Bill 2026
Capability Building underutilisation reflects structural barriers – not low need
Submitted by: Christian Umali
29 May 2026
About this submission
I make this submission as someone who has worked across the systems this Bill affects: 12 years at Services Australia administering Medicare, as a Local Area Coordinator helping NDIS participants understand and use their plans, alongside experience with Plan Management, and as a Complaints Officer at the Aged Care Quality and Safety Commission handling serious incident notifications and provider compliance. These comments are my own and are offered constructively.
I want to raise one issue the funding changes in the Bill risk getting wrong: the assumption that low utilisation of Capacity Building supports reflects low need.
The issue
From the Local Area Coordinator Role, I repeatedly saw Capacity Building funding go unspent – not because the participants didn’t need it, but due to structural barriers in using it.
One participant I supported had Capacity Building funding for allied health therapy – speech pathology, with occupational therapy also indicated to build everyday living skills. They were unable to use it: they were unsure how to arrange the funding, and because they lived in a remote area, suitable therapists were scarce even once the process was clear. The funding went largely unspent – not because the support wasn’t needed, but because the system was too hard to navigate and the local market is too thin to deliver it.
In other cases the barrier was on the provider side: Capacity Building Supports are harder to claim against than Core, so providers preferentially take on Core work and supply runs thin. These are navigation, workforce, and market-design problems – not demand signals. Reducing Capacity Building daily activity allocations on the basis of underspend therefore risks penalising participants for failures in how the system is navigated, staffed and paid. These erodes the important supports that build the independence the Scheme exists to foster.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 3256
An opportunity in the Bill
The Bill’s claims-and-payments system uplift is a one-time opportunity to address one of these barriers rather than entrench it. How the new architecture verifies and settles claims will determine whether the current friction between Core and Capacity Building claiming is removed or hard-coded into the next generation of the Scheme. If claiming parity is designed in – so that a verified Capacity Building outcome settles as readily as a Core service – the provider disincentive that contributes to underutilisation is reduced, improving both participant outcomes and payment integrity.
Recommendations
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That low utilisation of Capacity Building supports be investigated as a navigation, workforce and provider-claiming issue before allocations are reduced on an assumption of low need.
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The committee seek detail on how the new claims-and-payments architecture will treat Capacity Building claims relative to Core, and whether claiming parity is an explicit design objective.
I would welcome the opportunity to expand on any of these points. Thank you for considering this submission.
Christian Umali
29 May 2026