Submission 331
., • Women WinnerWinnerNationalNationalViolenceHumanPreventionRights AwardAward 20011999
Winner Tasmanian Women's Safety Award 2008 With• Certificate of Merit Australian Crime & Violence Prevention Awards 2008 Disabili~ies Nominee UN Millennium Peace Prize for Women 2000 !tfA ~~Australia Nominee French Republic's Human Rights Prize 2003
'-t (W'NDA) Nominee National Disability Awards 2017Nominee UNESCO Prize for Digital Empowerment of Persons with Disabilities 2021
1 June 2026
Committee Secretary
Senate Standing Committees on Community Affairs
PO Box 6100
Parliament House
Canberra ACT 2600
Phone: +61 2 6277 3515 Email: community.affairs.sen@aph.gov.au
Dear Committee Secretary,
Re: National Disability Insurance Scheme Amendment (Securing the NDIS for
Future Generations) Bill 2026
Women With Disabilities Australia (WWDA) provides the attached Submissionand
SupportingEvidencePaperprepared for the Senate Community Affairs Legislation
Committee inquiry into the NationalDisabilityInsuranceSchemeAmendment (SecuringtheNDISforFutureGenerations)Bill2026. The paper sets out WWDA’s analysis of the gendered risks of the Bill and the safeguards required before any reforms proceed.
WWDA recommends that the Bill not proceed in the absence of a public, comprehensive gender impact analysis, and gender-responsive reforms co designed with women, girls and gender-diverse people with disability.
WWDA provide this submission along with 71 endorsements, including 45 organisational endorsements and 26 endorsements from academics and community leaders. Endorsing organisations bring expertise spanning:
- disability rights and representative advocacy,
- legal and human rights safeguards,
- gender equity,
- violence prevention and response,
- women’s health,
- First Nations and multicultural communities,
- regional and rural communities,
- poverty,
- workplace rights and
Submission 331
., ~ Women
With JJ••~-j Disabili~ies
t~-=~P Australia cr.,-.,.. ~ (VNvDA) ..,-
public policy. Endorsements from academics and disability community leaders, including AM and OAM recipients, add further expertise across:
-
disability law,
-
health systems,
-
digital health equity,
-
rural health,
-
supported decision-making,
-
social policy,
-
disability research,
-
service-system design and
-
lived experience leadership. These endorsements reflect broad support for WWDA’s analysis, key recommendation and call for gender-responsive reform.
WWDA would welcome the opportunity to provide further evidence and advice to support this essential analysis work and to assist the Committee’s consideration of the Bill.
Yours sincerely,
Sophie Cusworth
Chief Executive Officer
Women With Disabilities Australia
Endorsements
No II Organisational Endorsements ·1
I1 Antipoverty Centre 7
I2 Australian Autism Alliance (AAA) 73 Australian Federation of Disability Organisations (AFDO) 1: I 11 Australian Lawyers for Human Rights (ALHR) ’I 4
·1 5 Australian Women’s Health Alliance (AWHA) I’I 6 I Australian Multicultural Women’s Alliance (AMWA)
2
Submission 331
., ~ Women
With JJ••~-j Disabili~ies
AustraliaA) cr.,-.,......t~-:,r;~ ~:0 (VNvD ..,
No 11 Organisational Endorsements ·1
7 Central Australian Women’s Legal Service ·1 1:
8 11 Children and Young People with Disability Australia (CYDA) ·1
9 Disability Advocacy Network Australia (DANA) 1: II10 I! Down Syndrome Australia Consortium
I11 I: GOGO Foundation
12 Human Rights Law Centre (HRLC) ·1 I
- I13 IInclusion AustraliaI14 IIntrepidus Law
I15 I~Jean Hailes -
·1 16 ILJFA Purple Orange I17 yMid North Coast Legal CentreI18 -1 First Peoples Disability Network (FPDN)
-1. Full Stop Australia I19 =
I20 1: MS Australia =
21 -I National Aboriginal and Torres Strait Islander Women’s Alliance (NATSIWA) I -
National Ethnic Disability Alliance (NEDA) I22 - l
National Foundation for Australian Women (NFAW) I23 ll -National Regional, Rural, Remote and Very Remote Community Legal Network
24
(4Rs Network) Di I25 llNational Rural Women’s Coalition (NRWC)
I26 Older Women's Network NSW Inc (OWNNSW) l
I27 People with Disabilities Australia (PWDA) 7:
28 Physical Disability Australia (PDA) ·1 7·
29 Safe and Equal -y I
I30 Self Advocacy Resource Unit (SARU) 7I31 ILSingle Mother Families Australia (SMFA)
32 11 SydWest Multicultural Services- ·1
33 Team DSC ·1 l
34 -1 Villamanta Disability Rights Legal Service ·13
Submission 331
., ~ Women
With JJ••~-j Disabili~ies
t~-=~P Australia cr.,-.,.. ~ (VNvDA) ..,No Organisational Endorsements
35 Wesnet 36 Women In Poverty Inc.
37 Women’s Legal Centre ACT (WLCACT)
38 Women’s Legal Services Australia (WLSA)
39 Women’s Legal Service NSW
40 Women with Disabilities ACT (WWDACT) 41 Women with Disabilities Victoria (WDV) 42 Working with Women Alliance (WwWA)
43 Working Women’s Centre ACT (WWCACT)
44 Working Women’s Centre Australia (WWCA)
45 Young People In Nursing Homes National Alliance (YPINH) I l~
No II Academic / Disability Leaders Endorsements I -
1 Dr. Jane Alver, Canberra University 1: I -Leslie Arnott, Centre for Digital Transformation of Health at University of DI2 Melbourne
I3 IA/Professor Anna Arstein-Kerslake, University of Melbourne -I4 IProfessor Deborah Bateson AM, University of Technology Sydney (UTS)
- ·1 5 I, Jax Brown OAM11 Dr. Chloe Bryant, Torrens University Australia I6
7 -I Professor Angela Dew, Deakin University I
A/Professor Caroline Ellison, Adelaide University I8 lL
'I 9 Dr Mahima Kalla, University of Melbourne 1~
- I10 71 Professor Jackie Leach Scully, Disability Innovation Institute at UNSW
11 A/Professor Yvette Maker, University of Tasmania I I
12 Tricia Malowney OAM I 1:·1 13 1: Dr. Bronwen Merner, Centre for Health Equity at University of Melbourne
14 11 Dr. Darren O'Donovan, La Trobe Law School 'I
15 Dr. Amie O’Shea, Deakin University 'I I4
Submission 331 j Women
~, I With.~
Disabilities "1,(A. ~;t:....• Australia~ (W’NDA)
INo IAcademic / Disability Leaders Endorsements I16 IDr. Maya Panisset, University of Melbourne
I17 IA/Professor Tania Penivic, Deakin University
Dr. Rosalie Power, Translational Health Research Institute, Western Sydney
18 University □
19 Christina Ryan
20 Dr. Natalie Sheard, University of Melbourne
21 A/Professor Louisa Smith, Deakin University
22 Professor Linda Steele, University of Technology Sydney (UTS)
23 Dr. George Taleporos
24 Professor Jane Tomnay AM, University of Melbourne 25 Dr. Georgia van Toorn, University of New South Wales (UNSW)
26 A/Professor Jo Watson, Deakin University
Women With Disabilities Australia (WWDA)
(I) wwda.org.au @ +61 438 535 123 @ PO Box 407, Lenah Valley, 7008 TASMANIA
WWDA has Special Consultative Status with the Economic and Social Council of the United Nations
Submission 331
Women
With
Disabilities
Australia
(WWDA)
Submission
Gendered Risks of the NDIS Amendment Bill 2026
For submission to the Senate Community Affairs Legislation
Committee: NationalDisabilityInsuranceSchemeAmendment
(SecuringtheNDISforFutureGenerations)Bill2026
Women With Disabilities Australia (WWDA)
May 2026
Submission 331
Women
With
Disabilities
Australia
(I/vi/I/DA)
Publishing information The moral rights of the authors have been asserted. Women With Disabilities Australia [WWDA] (2026). Gendered Risks of the NDIS Amendment Bill 2026 Submission and Supporting Evidence Paper prepared for the
Senate Community Affairs Legislation Committee inquiry into the National Disability
Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill
- May 2026. Written by Dr. Diana Piantedosi, Senior Manager, Policy & Advocacy: Hobart, Tasmania.
Authorised by:
-
Sophie Cusworth, Chief Executive Officer Author:
-
Dr. Diana Piantedosi, Senior Manager, Policy & Advocacy
Acknowledgement of Country
The authors acknowledge the traditional owners of the land on which this publication was produced. We acknowledge First Nations people’s deep spiritual connection to this land. We extend our respects to community members and elders past, present and emerging.
Submission contact
Sophie Cusworth
Chief Executive Officer, Women With Disabilities Australia
AboutWWDA
Women with Disabilities Australia (WWDA) is the National Disabled People’s Organisation and National Women’s Alliance for women, girls and gender diverse people with disability in Australia. WWDA is governed, run, led, staffed by, and constituted of women, girls and gender diverse people with disability. Our work is grounded in a human rights framework across civil, political, economic, social and cultural rights.
Women With Disabilities Australia (WWDA)
• wwda.org.au @ +61 438 535123 {!) PO Box 407, Lenah Valley, 7008 TASMANIAWWDA has Special Consultative Status with the Economic and Social Council of the United Nations
Submission 331
Gendered Risks of the NDIS Amendment Bill 2026
Recommendation
The National Disability Insurance Scheme Amendment (Securing the NDIS for Future
Generations) Bill 2026would change who the NDIS recognises, who it excludes, what support it funds, and what costs it shifts back to families and other service systems.
WWDA recommends that the Bill not proceed in the absence of a comprehensive, public gender impact analysis and co-design of gender responsive reforms with women, girls and gender-diverse people with disability.
This is necessary because the NDIS already underserves women. Women make up more than half of people with disability in Australia, but just over a third of NDIS participants. These reforms risk deepening that exclusion before Government has built the alternative supports, safeguards and service systems people are being told to rely on. WWDA’s key concerns The Bill gives Government broad powers to tighten access, reduce supports, cap funding and shift people to other systems before the rules, assessment tools, safeguards and foundational supports have been designed, t ested or made available. This creates t hree immediate risks:
- People may lose access before any alternative exists.
- Costs and care will shift onto families, especially women.
- Future rules, tools and evidence settings may reproduce existing gender bias.
Government cannot cut first and design the replacement systems later. Right now, for many people with disability, there is nowhere else to go.
- Tightened eligibility will deepen gendered exclusion. The Bill risks narrowing access through new functional capacity thresholds, permanence tests, treatment requirements and exclusions based on other service systems. These test s may appear neutral, but they will operate in systems where women, girls and gender-diverse people already face delayed diagnosis, clinical dismissal, under-documentation and barriers to specialist evidence. This is particularly serious for people with fluctuating, episodic, fatigue-related, pain related, trauma-related, psychosocial and chronic health conditions.
2
Submission 331
Gendered Risks of the NDIS Amendment Bill 2026
These disability experiences are often harder to document through narrow functional assessments and are more likely to be under-recognised in health and disability systems.
WWDA is concerned that the Bill may:
-
treat delayed or unaffordable treatment as evidence that a person has not exhausted “all appropriate treatment”;
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assume health, aged care, compensation or other systems can provide disability support when they often cannot;
-
fail to recognise that episodic disability can have permanent functional impact;
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push people with degenerative conditions out of early support, creating higher lifetime costs; and
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weaken protections for people who turn 65 and still require disability support.
Key message for Government: eligibility reform cannot proceed safely until alternative supports are real, available, timely, safe, disability-competent and gender-responsive.
- Support cuts will shift costs and safety risks onto women. The Bill risks reducing supports that enable daily living, community participation, safety, autonomy and work. When funded supports are reduced, the need for care and support does not disappear. It shifts to unpaid carers, who are disproportionately women. This will affect mothers, partners, daughters, sisters and friends, including many women with disability who already provide care while managing their own support needs.
WWDA is concerned that support reductions, caps and lower-cost alternatives may:
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push more unpaid care onto women;
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reduce women’s workforce participation and economic security;
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isolate women and gender-diverse people with disability from community safeguards;
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increase risks of violence, abuse, neglect and exploitation;
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replace individualised support with blanket caps or ratios that erase actualneed;and
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split whole-person support into artificial impairment categories that do not reflect real life.
3
Submission 331
Gendered Risks of the NDIS Amendment Bill 2026
Community participation is not optional. For many women and gender-diverse people w ith disability, it creates visibility, connection, safety and routes to help. Cutting these supports can remove the regular contact that helps people be seen, known and able to report harm.
Key message for Government: support reductions will not remove need. They will shift cost, care and risk onto women and families, leading to crisis-driven responses in other systems.
- Delegated evidence, budget and automation settings may entrench bias. The Bill delegates major decisions to future rules, technical advice, evidence standards, budget methods and computer-assisted processes. Those mechanisms may shape access, support needs and funding before Parliament and the disability community can scrutinise their impact.
WWDA is particularly concerned that future rules may:
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prioritise potentially gender bias published research over participant outcomes and practitioner evidence;
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discount supports used by people whose disability experiences are under-researched;
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limit the evidence that assessors can consider;
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use historical data that already reflects gender bias, lower service access and under-utilisation;
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use automated or computer-assisted action without adequate transparency, review rights or bias testing; and
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allow budget methods to shape identified support needs, not just funding levels.
Apparently neutral evidence systems are not automatically fair. Research gaps, diagnostic bias, poor data and under-recognition of women’s disability experiences can all become exclusion mechanisms if Government does not build safeguards into the Bill and rules.
Key message for Government: future rules and automated settings must not make women pay for gaps in research, diagnosis and service access.
4
Submission 331
Gendered Risks of the NDIS Amendment Bill 2026
What WWDA are calling for The scale of the proposed changes requires more than limited references to gendered impacts in the explanatory memorandum. A comprehensive gender impact analysis must occur before the Bill progresses. It should identify who will be harmed, how costs will shift, which groups face exclusion, and what safeguards must be built into legislation and rules. Retrospective monitoring w ill come too late for people who lose support, leave work, become isolated, or enter crisis.
Co-design also cannot operate as a safeguard after key policy decisions have already been made. Genuine co-design requires women, girls and gender-diverse people w ith disability to shape the reform settings before they are settled.
WWDA’s recommendation to Government: WWDA recommends that the Bill not proceed in the absence of a public, comprehensive gender impact analysis, and gender-responsive reforms co-designed with women, girls and gender-diverse people with disability.
At minimum, Government must demonstrate that:
-
foundational supports and other service systems are available before people are redirected away from the NDIS;
-
no one loses support before safe and sufficient alternatives exist;
-
eligibility tests recognise fluctuating, episodic, chronic, psychosocial, pain- related and trauma-related disability;
-
support reductions do not increase unpaid care, isolation, violence risk or economic insecurity;
-
budget methods, assessment tools and evidence rules are transparent, reviewable and bias-tested; and
-
any delegated power includes parliamentary scrutiny, lived-experience oversight and gender-responsive safeguards.
The bottom line The primary gender risk does not sit in one provision of this Bill. It arises from the interaction between narrower eligibility, delegated funding powers, support caps, impairment-specific attribution, restricted reassessment, evidence rules and reliance on service systems that are already failing many women, girls and gender diverse people with disability. The Bill proposes to embed high-risk settings before Government has shown how it will prevent gendered exclusion, care-shifting, violence risk and biased decision-making.
5
Submission 331
Supporting Evidence Paper
Gendered Risks of the N DIS Amendment Bill 2026 For submission to the Senate Community Affairs Legislation
Committee: National Disabtlity Insurance Scheme Amendment (Securing
the NDIS for Future Generations) BIii 2026
Women With Disabilities Australia (WWDA)
May 2026
Purpose of this paper WWDA’s submission provides a concise statement of our position and recommendations to the Committee. This supporting evidence paper provides the detailed evidence, examples and risk analysis that inform that submission. It is intended to assist the Committee, Ministerial offices and sector stakeholders to understand the gendered implications of the Bill across eligibility, support reductions, delegated powers, evidence rules and implementation risks.
Issue summary: This Bill will shape who the NDIS recognises, who it excludes, what support it funds and what care it shifts back to families and informal supports. In a scheme with documented gender inequities, proceeding without a detailed public gender impact assessment risks entrenching those inequities.
Women With Disabilities Australia (WWDA)
• wwda.org.au @ +61 438 535 123 @) PO Sox 407, Lenah Valley, 7008 TASMANIAWWDA has Special Consultative Status with the Economic and Social Council of the United Nations
Submission 331
Gendered Risks of the NDIS Amendment Bill 2026
Table of Contents
Purpose of this paper ……………………………………………………………………………………………………………… 6 Executive Summary ………………………………………………………………………………………………… 8 Key Message #1: The NDIS already underserves women. This Bill will make that worse. ………………………………………………………………………………………………………………………………………….. 8 Table 1: Key Concerns …………………………………………………………………………………………….. 9
-
Tightened eligibility will deepen gendered exclusion ………………………………………. 10 Key Message #2: Compensation is not lifetime disability support. ………………………….. 11 Key Message #3: Early support prevents higher lifetime costs. ………………………………… 11 Key Message #4: Episodic disability has permanent functional impact. ……………….. 12 Key Message #5: Health costs and availability should not decide NDIS access. … 12 Key Message #6: Turning 65 should not mean losing disability support. ………………. 13 Table 2: Eligibility safeguards ……………………………………………………………………………….. 13
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Support cuts will shift costs and safety risks onto women ……………………………… 15 Key Message #7: NDIS cuts shift unpaid care onto women. …………………………………….. 16 Key Message #8: Isolation creates conditions for violence and neglect. ………………. 17 Key Message #9: Blanket caps erase individual need. …………………………………………………. 17 Key Message #10: Whole-person support cannot be split into impairment silos.. 18 Key Message #11: Crisis can make people “uncontactable”. ……………………………………… 18 Key Message #12: Supply delays should not erase approved supports. ………………… 18 Key Message #13: Crisis support should not have to become “ongoing”. …………….. 19 Table 3: Support safeguards …………………………………………………………………………………. 19
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Delegated evidence and budget settings may entrench bias. …………………………. 21 Key Message #14: New evidence rules can make women pay for research gaps. 22 Table 4: Evidence safeguards ……………………………………………………………………………….. 22 Conclusion …………………………………………………………………………………………………………….. 24 Language note ………………………………………………………………………………………………………. 24
7
Submission 331
Gendered Risks of the NDIS Amendment Bill 2026
Executive Summary
The Bill proposes substantial changes to NDIS access, planning and supports. The Bill would establish broad powers before the rules, assessment tools, safeguards and adult foundational supports needed to prevent harm have been designed, tested or made available. The Government has repeatedly cited the 2023 NDIS Review as justification for reform 1, yet the Review itself cautioned against selective or piecemeal implementation, stating that its 26 recommendations and 139 supporting actions are “interdependent” and “must be implemented as a package to achieve a more inclusive and fairer Australia for all people with disability2.” Peer reviewed analysis has also found that the 2023 NDIS Review did not adequately examine gender inequities in the Scheme3. The Bill therefore proceeds from an evidence base that does not fully account for gendered disability experience, in the context of persistent gendered inequities identified in the Joint Standing Committee’s latest annual report4.
The Explanatory Memorandum acknowledges some gendered impacts, particularly the gendered nature of unpaid care5. However, it does not provide a detailed gender impact analysis of how the reforms will affect participants. It gives limited attention to women, girls and gender-diverse people w ith disability, despite evidence that they already face barriers across the NDIS, health, mental health, family violence, housing and care systems.
WWDA is deeply concerned that the proposal will compound these known inequities. Given the scale of the proposed reforms, government should transparently assess gendered impacts before the Bill proceeds. Retrospective monitoring or consultation after key policy decisions have been made cannot substitute for a prospective gender impact assessment. Genuine co-design requires affected communities to shape policy design before settings are settled, particularly where reforms may reduce access to supports, shift costs to unpaid carers, or increase unmet need.
Key Message #1: The NDIS already underserves women. This Bill will make that worse.
Women make up over half the disability population6 but just over a third of NDIS recipients7.
Women’s participation rates in the scheme have remained stagnant at 37-38% since scheme inception8. Women also find it harder to access the scheme as they get older9. There are similar rates of access approval for male and female children aged 0-14. However, from ages 15+ male access requests are approved at far higher rates than females and applicants gendered ’other’10. This gendered gap widens for each age band through to 64.
8
Submission 331
Gendered Risks of the NDIS Amendment Bill 2026
Research11 indicates three reasons why women are underserviced by the NDIS:
-
Women are under diagnosed with conditions commonly accepted by the NOIA (e.g. autism) while being far more likely to be diagnosed with chronic health or autoimmune conditions that are less likely to be accepted by the NOIA;
-
Women are socialised to deemphasise their own needs, which may mean women are “less effective self-advocates than men”12; and
-
The gendered nature of caring responsibilities alongside the complications women face in having these responsibilities supported, particularly in relation to parenting.
WWDA has long advocated for the establishment of a gender strategy to address persistent gender inequality in the NDIS13. The Joint Standing Committee’s latest annual report recently affirmed this call for action 14 . It recommended restarting the currently ‘shelved’ NDIS Gender Equity Strategy, improving gender data collection and reporting, and strengthening responses to violence 15. The design of the current reforms is contrary to this guidance and risks significantly worsening known inequities.
Table 1: Key Concerns
1. Tightened eligibility will 2. Support cuts will shift 3. Delegated evidence
deepen gendered costs and safety risks and budget settings may
exclusion. onto women. entrench bias.
Functional capacity Cuts to social, civic and TAG design, standardised
thresholds, peer community participation, tools, peer-reviewed
comparison, permanence caps, ratios, lower- "generalisable" research,
tests and alternative- cost alternatives and limits on practitioner
service exclusions may tighter reassessment evidence, automated
miss fluctuating, may isolate women and recommendations
episodic, fatigue, pain, gender diverse people, and budget methods
trauma-related and co- reduce natural may reproduce gender
occurring impairments. safeguards and push bias already present in
These settings will unpaid care onto diagnosis, health
operate in a Scheme that mothers, partners, systems, evidence,
already underserves daughters and sisters. service use and planwomen. utilisation data.
9
Submission 331
Gendered Risks of the NDIS Amendment Bill 2026
- Tightened eligibility will deepen gendered exclusion The NDIS already has documented gender inequities in access. Women have lower participation rates than men16, the access gap widens from adolescence17, and the Joint Standing Committee on the NDIS has recommended that the NDIA recommence work on the shelved Gender Equity Strategy18. These issues should shape how Parliament assesses any Bill that tightens who can enter the Scheme, remain in the Scheme, or seek reassessment when support needs change.
The eligibility reforms create a particular risk because they narrow what decision makers can recognise as disability-related need. Functional capacity, permanence, treatment history and access to other service systems may appear neutral on paper, but each relies on evidence produced by systems where women, girls and gender diverse people already experience delayed diagnosis, clinical dismissal, under documentation and unsafe or unavailable services. Without safeguards, the Bill may treat these existing inequities as evidence of lower need or ineligibility.
The current reform focus has centred on developing a support system for Thriving Kids. However, the NDIS Review also recommended a parallel expansion of home and community care supports for adults under 65 with lower-intensity and episodic needs, including people with chronic health conditions19. This adult support system has not yet been built. Many people are currently directed to health, aged care, compensation, insurance or other service systems that either do not provide the required disability supports, provide them only for a limited period, or provide payments that do not meet lifetime disability-related costs. Access decisions must therefore turn on whether another system actually provides timely, safe, accessible, disability-competent and sufficient support in practice, rather than whether another system could theoretically be responsible for providing it.
The Bill may make episodic disability harder to recognise by requiring people to exhaust “all appropriate treatment” before their impairment is considered permanent. This will disadvantage people with disability related to chronic health conditions, particularly where timely treatment, rehabilitation and allied health support are unaffordable, unavailable or inaccessible. WWDA’s 2025 Economic Security Survey found that 75% of respondents experienced health insecurity in the past six months, including delaying or missing GP or specialist appointments, or being unable to access prescription medication because of money shortages20. It also found that 75% lived with one or more chronic health conditions, and 60% said physical health created a barrier to seeking or keeping work21.
Chronic condition management plans provide only five subsidised allied health sessions per year22. For many people, this is not enough to manage episodic disability, maintain function, prevent deterioration or stay engaged in work. This creates a user-pays access barrier. People with money, transport and local services may be better able to show they have exhausted treatment. People without those
10
Submission 331
Gendered Risks of the NDIS Amendment Bill 2026
resources may be excluded because they could not access the treatment the Bill expects them to have tried. This would increase inequity, delay support, worsen preventable deterioration and push more people out of work. It would also increase downstream costs where delayed support leads to avoidable hospitalisations and more intensive support needs.
Public reporting has already linked loss or denial of NDIS support to people choosing voluntary assisted dying23. This underscores the seriousness of tightening disability access before safe, adequate and timely alternatives exist. In an already gender-unequal Scheme, these risks require prospective gender and human rights assessment before the Bill proceeds. Table 2 identifies the minimum safeguards needed to prevent that outcome. Eligibility and reassessment decisions must recognise functional impact over time and in context. They must also account for inaccessible treatment, failed service systems, fluctuating disability and urgent safety changes before people are pushed further into crisis.
Key Message #2: Compensation is not lifetime disability support. A WWDA member shared that she sustained a brain injury and requires lifelong disability support. Under Victoria’s Transport Accident Commission (TAC) scheme, she may receive about $80,000 once, minus legal fees, while her disability support costs exceed $40,000 each year. The TAC does not fund some disability supports, including support coordination, and most domestic supports stop after five years. She also could not access t reatment at the time of injury because she had no money, lived five hours from specialist rehabilitation, and left hospital without being told what treatments existed. WWDA also understands that, after a workplace injury, WorkSafe supports are reassessed and often stop after two years24. The Bill risks treating compensation schemes as an alternative to t he NDIS even when they do not provide adequate, ongoing disability support.
Key Message #3: Early support prevents higher lifetime costs. Degenerative conditions often require early and ongoing support to maintain function, delay deterioration and prevent higher future costs. Multiple sclerosis is one example and it affects three times more women than men in Australia25. Australian research26 found that NDIS packages for people with multiple sclerosis rose sharply with disability severity, from AU$34,224 for ‘mild’ disability to AU$114,585 for ‘severe’ disability. The study also found “a striking variability in packages approved” and that “restricted mobility seems to be the driving factor”.
Once people were no longer employed, plan values were significantly higher: AU$88,439 for unemployed participants compared with AU$33,881 for
11
Submission 331
Gendered Risks of the NDIS Amendment Bill 2026
employed part icipants. The Bill risks denying early, preventative disability support until functional decline becomes severe, even though timely support can help people maintain function, participate in work and reduce higher future Scheme costs.
Key Message #4: Episodic disability has permanent functional impact. A WWDA member with multiple sclerosis described episodic disability as “not knowing what body you will wake up in”. During exacerbations, she experiences leg spasticity, loss of movement on one side of the body, brain fog, severe fatigue, visual disturbances, nerve pain known as the “MS hug”, and reduced fine motor function that makes brushing hair, vacuuming and cleaning almost impossible. The severity of symptoms fluctuates, but the functional impact is permanent. She described the vigilance required to monitor her body, track warning signs, pace activity and constantly adjust daily routines t o prevent exacerbations that can st op functioning for days. NDIS-funded cleaning and allied health supports helped her maintain routines, use adaptive equipment, live independently, and remain in full-time work. Functional measures must also capture what a person forgoes to perform a task. A person may get through a workday only by giving up cooking, cleaning, social connection, exercise or recovery time afterwards. A functional threshold that only captures visible impairment at one point in time will miss the constant self management work and trade-offs required to live with episodic disability.
Key Message #5: Health costs and availability should not decide NDIS access. A WWDA member with multiple sclerosis entered the NDIS Early Intervention stream. As the ‘Key message 4’ shows, her disability is episodic, but managing it requires constant vigilance. Her NDIS plan funded the allied health support she needed to understand her body, recognise warning signs, manage fatigue, use adaptive equipment, reduce exacerbations and st ay in full-time work. It also funded weekly cleaning, which helped her maintain her home, preserve dignity and allow her to live independently. Five subsidised allied health sessions a year would not have come close to meeting that need, and the health system does not provide practical disability supports such as cleaning. If the Bill requires people to exhaust “all appropriate treatment” before their impairment is recognised as permanent, access will depend on who can pay to prove they have tried enough. People with money, transport and local services will be better placed to build the treatment history the Bill demands.
12
Submission 331
Gendered Risks of the NDIS Amendment Bill 2026
People without those resources may be excluded because they could not access the very treatment the law expects them to have completed.
Key Message #6: Turning 65 should not mean losing disability support. Current NDIS settings allow a person who enters the Scheme before 65 to remain in the Scheme after they turn 65. This safeguard matters because aged care is not resourced to meet disability support needs. For example, the ABC has reported Graham Crossan is 80 and has advanced motor neurone disease. He cannot walk, eat, talk or breathe without support, yet he was denied increased home care after an aged care assessment algorithm found he was not eligible27. His wife Gaynor provides 24-hour care, has injured herself trying to move him, and says “both our safety” is at risk28. The Bill risks weakening the protection current participants rely on if future rules treat aged care as an alternative to the NDIS, despite evidence that it cannot safely meet high disability support needs.
Table 2: Eligibility safeguards
Bill lever Gendered risk Minimum safeguards
Functional May underestimate disability Functional capacity
capacity when functional impacts are assessment must capture
thresholds fluctuating, episodic, fatigue- ordinary and worst days,related, pain-related, reliability, safety, duration, psychosocial, neurodivergent recovery time, fluctuation, or trauma-related. This risk is masking, co-occurring greater for women and impairments, and violence gender-diverse people who related barriers to have adapted by withdrawing participation. from work, study, parenting, caring or community life.
Reliance on peer Peer comparison can Remove peer comparison
comparison compound this risk where the from functional capacityassumed comparator reflects assessment. Assessment male-pattern participation, should focus on the person’s and fails to account for the actual functional impact, supports, safety conditions support needs and barriers to and resources required for participation, including how women and gender-diverse disability interacts with people to participate in work, gender, violence, caring roles,
13
Submission 331
Gendered Risks of the NDIS Amendment Bill 2026
Bill lever Gendered risk Minimum safeguardsstudy, parenting, caring or service access and economic community life. inequality.
Permanence tied Risks turning health-system Permanence must not be
to "all appropriate failure into NDIS exclusion denied because treatment
treatment" where diagnosis or treatment was inaccessible, unsafe,is delayed, unaffordable, unaffordable, inappropriate or unsafe, culturally delayed by gender bias. The inappropriate, traumatising, Explanatory Memorandum and regionally unavailable or Bill contemplate clinically contested. This will circumstances where it may disproportionately affect be inappropriate to determine people whose conditions are there are treatment options degenerative and/or poorly available29. This must include recognised in health systems, considerations of safety, including women with trauma, cost, culture, regional chronic health-related, access and availability. psychosocial, pain-related or trauma-related disability.
Alternative May redirect people to No exclusion based on
supports through health, mental health, aged another service syst em unless
other systems care, compensation, housing that service is actuallyor family violence systems available, timely, accessible, that are unavailable, delayed, disability-competent, safe, unsafe, not disability- culturally appropriate and able competent, or unable to to meet the person’s support meet disability support need. needs. This risks shifting unmet need onto women, families and informal supports, and crisis systems.
Sequencing with Tightened access may push Do not commence t ighter
foundational people into service gaps access or alternative-service
supports before foundational supports exclusions until foundationalexist, particularly adults with supports are funded, available, chronic, episodic, accessible, disability psychosocial or fluctuating competent and gender disability. This will responsive. For example, the disproportionately affect 2023 NDIS Review women and gender-diverse recommended joint people who already face investment in expanded
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Bill lever Gendered risk Minimum safeguardsunder-recognition across home and community care health and disability systems, programs for adults under 65 and a higher prevalence of with lower-intensity and chronic health conditions. episodic needs, including a national benchmark of around 235,000 places30.
"Significant and May miss urgent, time-critical Create urgent and fast-
ongoing" and changes in support need, tracked reassessment or
"unanticipated" including gender-based variation triggers for gender-
reassessment violence, homelessness, carer based violence, unsafe
thresholds breakdown, pregnancy, housing, carer loss, episodicparenting, relapse, hospital deterioration, parenting, discharge, episodic pregnancy, hospital discharge deterioration or sudden loss and other safety risks. Clarify of informal support. A person that “unanticipated” means should not need to prove a unanticipated when the plan crisis is “ongoing”, or defend was approved. Do not require why an unsafe change was crisis or instability to become “unanticipated”, before ongoing before support can support becomes available. be adjusted.
- Support cuts will shift costs and safety risks onto women This section addresses how the Bill may reduce supports that contribute to safety, autonomy and participation. Changing the landscape identifies violence against women and girls with disability as a human rights issue shaped by gender inequality and ableism31. The Disability Royal Commission also found that reducing isolation, strengthening safeguards and supporting community inclusion are central to preventing violence, abuse, neglect and exploitation32.
The Bill sits within a care system that already relies heavily on unpaid labour. Current NDIS settings assume support from families, carers, informal networks and the community. In 2020, replacing unpaid care with paid support was estimated to cost $77.9 billion33, more than twice the cost of the NDIS over the same period34. Reducing funded supports therefore shifts costs rather than removing them.
That costs shift is gendered. Women are the majority of primary carers:
-
12.3% of Australian women identify as carers, representing 71% of all primary carers35
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Nearly 90% of primary carers for children are women36 15
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- Women often carry dual care responsibilities for elderly parents as well as their children often referred to as “the sandwich generation”37
Many carers have disability t hemselves. Reduced supports will increase unpaid care, coordination, transport, supervision and advocacy. This creates a direct risk to women’s workforce participation, income and financial security. Changes to support settings will reduce gendered productivity gains in three ways:
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Disabled women will lose supports that enable work: Women with disability will be pushed to reduce hours, leave work or lose pathways int o employment if funded supports are cut, capped or replaced with unsuitable alt ernatives.
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Unpaid care will increase: Parents, partners and carers, who are disproportionately women, will be pushed to reduce paid work or leave the workforce as more support shifts back to families.
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Paid care work will contract: The disability support workforce is highly gendered, 7 in 10 disability support workers are female38. Broad reductions to support funding will reduce paid care work, increase job insecurity and weaken women’s economic security across the care economy.
In addition to these risks, the Bill appears to creat e enduring powers that could be used across broader support categories, including supports that maintain daily living, personal care, safety and community participation. This creates a structural safety risk because future determinations could reduce funding for whole classes of plans or participants without assessing individual circumstances. The Bill also shifts the meaning of “reasonable” toward what the Scheme can sustainably fund, rather than what the person needs to access support in practice. Where funded amount s fall below actual support cost s, the gap will be carried by participants, families and unpaid carers, with predictable gendered impacts. The minimum safeguards should prot ect safety and recovery related supports, preserve individualised support where group or family-based options are unsafe, ineffective or promote segregation from the community, and require gender impact assessment before caps, class-based reductions or funding rules override assessed need.
Key Message #7: NDIS cuts shift unpaid care onto women. The ABC have reported Penny Lalor entered the NDIS after a stroke39. The Scheme enabled her to live at home, walk short distances w ith assistance and use her wheelchair outside the house. After her plan was cut by about 50 per cent, her mobility regressed, she was hospitalised twice, and her daughter Caitlin cut back paid work and moved in to provide care. This shows what happens when funded support is reduced without removing the need for care. At scale, these cuts will push more unpaid care onto daughters, mothers,
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partners and sisters, reducing women’s workforce participation, increasing carer exhaustion and result in worse outcomes for participants. Where families cannot sustain that care, more people may enter residential or institutional settings, including younger people forced into aged care, resulting in higher overall costs and worse participant outcomes.
Key Message #8: Isolation creates conditions for violence and neglect. Ann Marie Smith’s death shows why community part icipation is a safety issue. She had cerebral palsy, lived alone, received NDIS-funded care and had very limited contact outside one closed support relationship40. Police said she had been left in the same chair day and night, was malnourished, in septic shock and died in circumstances described as “likely preventable”. Isolation was identified as a central risk factor, with advocates stating that safeguarding requires “multiple eyes” and “mult iple people” in a person’s life41. The Disability Royal Commission examined what had been learnt since her death and stated that individual cases must identify t he “policy and regulatory issues” needed t o give practical effect to Australia’s human rights obligations42. Reducing social, civic and community participation supports risks cutting away the regular contact, visibility and informal safeguards that help people be seen, known and able to report harm. For women with disability, who already experience higher rates of violence, these cuts risk deepening isolation and worsening conditions where violence, abuse, neglect and exploitation are hidden.
Key Message #9: Blanket caps erase individual need. Maximum intensity, ratio powers and support determinations could affect supports people rely on for daily living, including personal care, mobility, communication, behaviour support and community access. These needs cannot be safely reduced through assumptions about an “average” participant. Even within the same diagnosis categories, t here remains significant variability in presentation. For example, research describes MS as “a very variable disease” and found NDIS package values ranging from $4,901 to $516,703, with core support for people with lower assessed disability ranging from $5,000 to $72,00043. The same risk applies across disability groups. Government analysis reported by The Guardian found proposed social, civic and community participation cuts would affect some part icipants more heavily, including people wit h visual impairment, psychosocial disability and Down syndrome, because some people need significant support to access the community even where they need less day-to-day support44. Blanket caps, intensity limits and ratios risk cutting supports that make daily life safe, dignified and possible.
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Key Message #10: Whole-person support cannot be split into impairment silos. For example, a participant may meet NDIS access through psychosocial disability and also have ADHD that does not meet access. They receive psychology support to manage distress, executive function, emotional regulation and daily routines. In practice, the psychologist must work with the whole person, not divide each session into minutes caused “directly” by one impairment or another. The same problem arises where a person has an eligible impairment (such as Autism) and chronic pain. Pain, fatigue, sensory distress, mobility, cognition and trauma can interact in ways that change how support must be delivered. The Bill risks replacing whole-person support with artificial attribution tests that practitioners cannot apply safely in practice.
Key Message #11: Crisis can make people “uncontactable”. A participant escaping violence may leave home quickly, change phones, lose documents, move through crisis accommodation or avoid contact for safety reasons. Under the Bill, being “not contactable” could lead to plan suspension and revocation of participant status. This creates a serious safety risk. A person in crisis may lose the very supports that help them stabilise, communicate with services, attend appointments, secure housing and stay safe. Safeguarding steps must be required before suspension or revocation, especially where violence, homelessness, coercive control, hospitalisation or crisis accommodation may explain why a participant cannot respond.
Key Message #12: Supply delays should not erase approved supports. A participant may have approved capital funding for home modifications, a hoist or essential equipment, but cannot use the funding before the plan ends because assessments, installation, quotes or suppliers are delayed. This does not mean the support is unnecessary. It means the system has not delivered it in time. Use-it-or-lose-it settings risk removing approved supports because of delays outside the participant’s control. This risk will be greater for women in regional and remote areas, women managing violence or unstable housing, a11d women balancing disability support with caring responsibilities.
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Key Message #13: Crisis support should not have to become “ongoing”. A participant’s support needs may change quickly because they are pregnant, parenting alone, leaving violence, losing informal care or moving through unsafe housing. Under the Bill, a participant may need to show that a change is “significant and ongoing” before a reassessment occurs. That threshold may miss urgent, time-critical support needs. A person should not have to prove that crisis has become permanent before support is adjusted to keep them and their children safe.
Table 3: Support safeguards
Bill lever Gendered risk Minimum safeguards
SCCP and Class-based reductions may Blanket cuts are contrary to
capacity-building reduce supports that prevent the individualised design of
reductions isolation and enable safety, the NDIS and createrecovery, education, unacceptable risk45. This is employment and civic particularly the case for participation. Substituting violence, safety and recovery group supports may be related supports. A unavailable in regional and comprehensive i ntersectional remote areas or unsafe/ impact analysis must be ineffective for people with conducted, and participants’ trauma or psychosocial individual circumstances must disability. be considered, before reductions apply. Individualised and 1:1 supports must be preserved where group settings are unsafe, inaccessible, ineffective, oir promote segregation.
Caps, maximum Ministerial ceilings may No cap or class determination
intensity/ratios convert assessed need into a without an individual
and support lower funded amount for dedicated gender impact
determinations whole classes of participants, assessment, strengthenedwithout plan-by-plan merits parliamentary scrutiny, an review. This may miss individual safety/complexit y gendered safety, parenting, override, and intersectional trauma, thin markets and monitoring of outcomes. interacting impairments.
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Bill lever Gendered risk Minimum safeguards
Reasonable and Shifting "reasonable" toward Require any change to
necessary what is reasonable for the reasonable and necessary
definitional Scheme to fund may allow criteria to be tested through a
changes funded amounts to fall below dedicated gender impactthe actual cost of providing assessment. Funding or acquiring supports. This decisions must consider the can create a gap between real cost of accessing assessed need and usable supports in practice, including support, shifting costs onto market availability, regional participants, families and costs, safety, informal care unpaid carers. Given unequal impacts and the participant’s income, wealth and caring economic circumstances. responsibilities, this gap will have gendered impacts.
Direct link to Undermines a whole-of- Restore or retain whole-of-
eligible person approach. Requiring person safeguards, or require
impairment each support need to be decision-makers to assesslinked directly to a qualifying cumulative functional impact impairment may force and interactions between artificial medical attribution impairments rather than when chronic illness, isolating one impairment per psychosocial disability, support need. trauma, neurodivergence and physical impairment interact.
Informal supports Reduced funded support will Informal care must not be
and lower-cost be absorbed by female and presumed available, safe or
alternatives gender-diverse carers and sustainable. Lower-costmay expose participants to alternatives must be assessed unsafe family or group for safety, autonomy, access, settings. This is a trauma impact and productivity risk: unpaid care prevention, not price alone. reduces workforce participation and financial security.
Unspent funds, Use-it-or-lose-it settings Blunt settings may
9O-day claims may treat low utilisation as disadvantage women in crisis
and suspensions lower need, when women and/ or treat low utilisation asmay underspend because lower need, when women may supports are unavailable, underspend because supports unsafe, delayed, disrupted by are unavailable, unsafe,
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Bill lever Gendered risk Minimum safeguardsviolence, or unsuitable for delayed, disrupted by fluctuating impairment. violence, or unsuitable for Removing or suspending fluctuating impairment. participants for contact issues could disadvantage women in crisis/ leaving violence.
- Delegated evidence and budget settings may entrench bias. This section addresses how the Bill may embed gender bias through the evidence, rules and tools that will drive future NDIS decisions. The concern is not only whether the Bill refers to evidence, but whose evidence counts, which data informs the rules, and whether future assessment systems can recognise disability experiences that have been under-researched, under-diagnosed or under-documented.
This is a gendered issue because women, girls and gender-diverse people with disability already experience systemic gaps in diagnosis, research, clinical recognition and service access. Peer-reviewed research has found that gender was largely absent from the NDIS Review’s findings and recommendations46, despite the Review being used as a key basis for reform. If the Technical Advisory Group, future rules and assessment tools do not correct this gap, they may reproduce it. The TAG must include experts with experience working w ith lived expertise and the disability community.
The Bill relies on mechanisms presented as objective, including standardised assessment, published research, generalisable evidence and computer-assisted action. These mechanisms require careful scrutiny because their inputs may reflect gender bias in medical knowledge47, delayed diagnosis48, lower service use, thin markets and unequal access to specialist evidence. Evidence standards should not treat limited published research as evidence that a support lacks benefit. They should also retain scope to consider evidence that a support improves outcomes for an individual participant. The Minister’s approach to accepting and weighing evidence should be transparent, reviewable and supported by published reasons.
The concern is particularly acute where future rules allow the budget method to shape the identification of support needs, not only the funding amount. The Explanatory Memorandum st ates that a needs assessment report is “not required to identify needs for NDIS supports” and that needs may be identified through either “the support needs assessment tool” or “provisions included in the budget
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method“49. Recent concerns about the aged care Support at Home model show the risk of formula-based tools producing support levels that do not meet daily needs50. Government should not delegate this design power before publishing and testing the budget method and support needs assessment process. A gender impact assessment must test how any formula, classification or budget rule will account for understated need, incomplete records, fluctuating disability, co occurring impairments and safety-related supports. Minimum safeguards should require gender expertise in rule-making and technical advice, allow lived and practitioner evidence, protect longitudinal evidence of fluctuation, and require bias testing, transparency, human accountability and review rights before automated or computer-assisted systems affect participants.
Key Message #14: New evidence rules can make women pay for research gaps. A woman with a fluctuating, pain-related or trauma-related disability may have years of practitioner evidence showing that a support helps her maintain function, avoid hospital, parent safely or remain in work. If future rules prioritise published, peer-reviewed and generalisable evidence over participant outcomes, decision-makers may discount the evidence that best explains her actual support needs. These risks treating under-researched disability experiences as unsupported, even where a support is demonstrably effective for the person.
Table 4: Evidence safeguards
Bill lever Gendered risk Minimum safeguards
Reliance on NDIS The Review is cited as a key The Technical Advisory Group
Review and basis for reform, yet research should be appointed through
future TAG finds it gave limited attention a transparent public EOIto gender inequities. The process. Require TAG Joint Standing Committee membership, terms of has also called for action on reference and rule-making NDIS gender disparities. processes to include gender, Without gender expertise in disability, violence, chronic future rules, tools and TAG illness, psychosocial, First advice, the Bill risks carrying Nations, CALO, rural/remote those gaps into and leaders experienced implementation. working with lived expertise. Publish advice, assumptions and gender impact modelling.
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Bill lever Gendered risk Minimum safeguards
Peer-reviewed Published research may Evidence standards must
and generalisable under-represent women, girls allow participant outcomes,
research and gender-diverse people practitioner evidence andwith disability. Limited practice evidence. The published evidence must not Minister’s approach to be treated as evidence that a accepting and weighing support lacks benefit, evidence must be transparent, particularly for fluctuating, reviewable and supported by chronic, psychosocial or published reasons. Decision trauma-related disability. makers must test evidence sources for gender and intersectional bias.
Limits on If future rules prescribe what Guarantee consideration of
external/ assessors must or must not participant evidence, treating
practitioner consider, participants with practitioner evidence, support
evidence delayed diagnosis, worker observations, safetyincomplete records or context and longitudinal complex co-occurring evidence of fluctuation. impairments may lose the Require reasons where evidence needed to explain relevant evidence is excluded functional impact. This is a or given limited weight. particular risk where women have been under-diagnosed or disbelieved in health systems.
Automation/ Automated or computer- No automated evaluative
evaluative assisted action can action without bias testing,
computer action reproduce bias from public criteria, humanhistorical claims, diagnosis, accountability, reasons, under-utilisation, missing correction rights, review records, unsafe service rights and independent access and advocacy monitoring by gender and disparities. “Objective” intersectional variables. criteria may still reflect Require systemic remediation unequal access to evidence where patterns of error are and support. identified.
Budget method Future budget rules may help Publish the budget method,
identifying decide what a person needs, assumptions and evidence
support needs not only how much funding base before commencement.they receive. Aged care Require gender impact
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Bill lever Gendered risk Minimum safeguardsreforms show the risk of assessment, individual formula-based tools assessment safeguards, producing support levels that participant correction rights, do not meet daily needs51 . reasons, review rights and monitoring of gaps between need and funding.
Conclusion
The Bill’s technical complexity and broad delegation of powers create material and potentially irreversible harms that disproportionately affect women, girls and gender-diverse people with disability. The current short consultation timeframe prevents meaningful lived-experience engagement, intersectional data analysis and the drafting of targeted safeguards. The Bill should not progress in the absence of a rigorous gender impact analysis that can: (a) identify who will be harmed, (b) quantify those harms, and (c) produce concrete legislative and rule-level solutions to prevent discriminatory and safety-critical outcomes.
The bottom line: The primary gender risk is not confined to any single provision. It arises from the interaction between narrower eligibility tests, impairment-specific attribution, delegated funding caps, restricted reassessment pathways, and reliance on service systems and unpaid carers that already operate unequally for women, girls and gender-diverse people with disability. If the Bill proceeds it will embed high-risk settings before the Government has shown how it will prevent gendered exclusion, violence risk, care-shifting and biased evidence from determining access and budgets.
Language note This submission reflects the overlapping experiences of marginalisation experienced by women, girls, nonbinary and gender-diverse people in our membership and broader community. Though these groups will experience gender discrimination and marginalisation, not all identify as women. WWDA’s submission may reflect the specific experiences of trans, non-binary and gender diverse people with disability. However, the experiences of trans, non-binary and gender-diverse people with disability warrant specific and direct exploration, particularly how they intersect w ith employment. WWDA recognises the limitation in aggregating our submission at a broader level of gender-marginalised people. WWDA aims to work in coalition with, rather than replicate the core work of organisations who represent and advocate for LGBTQIA+ people with disability. This submission uses ‘person first’ language (for example: women with
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disability). We acknowledge people describe their experience of disability in different ways, and for many people, ‘identity first’ language is a source of pride and resistance.
Endnotes
1 ExplanatoryMemorandum, NationalDisabilityInsuranceSchemeAmendment(SecuringtheNDISfor
FutureGenerations)Bill2026(Cth). (2026, May 14). Parliament of Australia. https://www.aph.gov.au/Parliamentary_Business/Bills_Legislation/Bills_Search_Results/Res ult?bId=r7487 2 Department of the Prime Minister and Cabinet. (2023, October). Working together to deliver the NDIS: Independent review into the National Disability Insurance Scheme: Final report. Commonwealth of Australia. https://www.ndisreview.gov.au/resources/reports/working-together deliver-ndis/, p. ii 3 Piantedosi, et al. 2025. 4 Joint Standing Committee on the National Disability Insurance Scheme, 2026, pp. 113- 115. 5 ExplanatoryMemorandum,NDISAmendment(SecuringtheNDISforFutureGenerations)Bill 2026(Cth), 2026, pp. 230- 231. 6 Australian Institute of Health and Welfare [AIHW]. (2024, April 23). Peoplewithdisabilityin Australia. https://www.aihw.gov.au/reports/disability/people-with-disability-in australia/contents/summary#HowMany 7 National Disability Insurance Agency [NDIA]. (Q3, 2025-26). Supplement E National 2025-26 Q3. https://dataresearch.ndis.gov.au/reports-and-analyses/quarterly-report-supplements. 8 Yates, S., Carey, G., Hargrave, J., Malbon, E., & Green, C. (2021). Women’s experiences of accessing individualized disability supports: Gender inequality and Australia’s National Disability Insurance Scheme. InternationalJournalforEquityinHealth,20, Article 243. https://doi.org/10.1186/s12939 021-01571-7 9 Disney, G., Devine, A., Kavanagh, A., Dickinson, H., & Yang, Y. (2025, February 17). NDISreformsaim tomaketheschemefairer.Butwe’vefoundthegroupsstrugglingtogainaccess. The Conversation. https://theconversation.com/ndis-reforms-aim-to-make-the-scheme-fairer-but weve-found-the-groups-struggling-to-gain-access-248562 10 Piantedosi, D. K., Wilding, R., Panisset, M. G., Molnar, L. I., Bryant, C., Gibbs, E., & Sawyer, A.-M. (2025). The presence and absence of gender and intersectionality in the 2023 NDIS review: A content analysis. InternationalJournalforEquityinHealth,24, Article
- https://doi.org/10.1186/s12939-025-02441-2 11 Yates, et al. 2021. 12 Yates, et al. 2021, p. 2. 13 Women With Disabilities Australia [WWDA]. (2024). WWDA position statement: NDIS Gender Strategy. https://wwda.org.au/wp-content/uploads/2024/04/WWDA-Position-Statement-NDIS
Gender-Strategy.pdf
14 Joint Standing Committee on the National Disability Insurance Scheme. (2026, March). Annual
reportno.1ofthe48thParliament:Chapter5,NDISparticipantfunding,eligibilityandaccess. Commonwealth of Australia. https://parlinfo.aph.gov.au/parlInfo/download/committees/reportjnt/RB000662/toc_pdf/A nnualReportNo.1ofthe48thParliament.pdf 15 Joint Standing Committee on the National Disability Insurance Scheme, 2026, pp. 113- 115. 16 Yates, et al. 2021.
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17 Piantedosi, et al. 2025. 18 Joint Standing Committee on the National Disability Insurance Scheme, 2026, p. 113. 19 Department of the Prime Minister and Cabinet, NDISReviewFinalReport, 2023, Recommendation 1.9 20 Women With Disabilities Australia [WWDA]. (2026, March 4). Health. https://wwda.org.au/our resources/publication/wwda-ees-survey-infodocs/ 21 WWDA, 2026. 22 Services Australia. (2025, November 1). AlliedhealthandotherprimaryhealthcarereferralsforGP chronicconditionmanagementplans. Australian Government. https://www.servicesaustralia.gov.au/allied-health-and-other-primary-health-care referrals-for-gp-chronic-condition-management-plans?context=20#accordion2 23 See for example: Landau, S. (2023, October 9). WhenhisNDISfundingwascut,palliativepatient
JimMillschosevoluntaryassisteddyingoverhospital. ABC
News. https://www.abc.net.au/news/2023-10-09/jim-mills-chose-voluntary-assisted-dying palliative-care-ndis/102928986; Cross, J. (2026, January 11). TonyLewischoosesvoluntaryassisted dyingafterbeingdeniedNDISaccessduetohisage. TheCourier Mail. https://www.couriermail.com.au/health/guides/ndis/tony-lewis-chooses-voluntary-assisted dying-after-being-denied-ndis-access-due-to-his-age/news story/f1b6d58b1476414ebf5e20159748f333
24 Victorian WorkCover Authority. (2021). Claimsmanual:3.3.5Afterthesecondentitlement
period. https://www1.worksafe.vic.gov.au/vwa/claimsmanual/Claims%20Manual/3-weekly payments/3-3-entitlement-periods/3.3.5_After_2nd_entitlement_period/3.3.5_-_3.3.5.1.htm 25 Burke, K. (2024, May 30). MultiplesclerosisisontheriseinAustralia,butit’snotallbadnews.
UNSW Newsroom. https://www.unsw.edu.au/newsroom/news/2024/05/Multiple-sclerosis-is-on-
the-rise-in-Australia-but-its-not-all-bad-news 26 Lechner-Scott, J., Reeves, P., Ribbons, K., Saugbjerg, B., & Lea, R. (2021). Do people with multiple sclerosis receive appropriate support from the National Disability Insurance Scheme matching their level of disability? A description of disease ‘burden and societal cost in people with multiple sclerosis in Australia’ (BAC-MS). AustralianHealthReview,45(6), 745–752. https://doi.org/10.1071/AH21056 27 Payne, S. (2026, February 28). AdvocatesfearMyAgedCarefundingalgorithmcouldbecome
Australia’snextrobodebt. ABC News. https://www.abc.net.au/news/2026-02-28/graham-crossan-
mnd-ndis-funding-fight/106397572 28 Payne, 2006. 29 ExplanatoryMemorandum,NDISAmendment(SecuringtheNDISforFutureGenerations)Bill 2026(Cth), 2026, pp. 63-65 30 Department of the Prime Minister and Cabinet. (2023). WorkingtogethertodelivertheNDIS: IndependentreviewintotheNationalDisabilityInsuranceScheme:Finalreport:Supportinganalysis. Commonwealth of Australia. https://www.ndisreview.gov.au/resources/reports/working-together deliver-ndis-supporting-analysis, p. 77. 31 Our Watch, & Women with Disabilities Victoria. (2022). Changingthelandscape:Anational resourcetopreventviolenceagainstwomenandgirlswithdisabilities. Our Watch. https://www.ourwatch.org.au/change-the-story/changing-the-landscape 32 Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. (2023,
September 29). Finalreport:Executivesummary,ourvisionforaninclusiveAustraliaand
recommendations. Commonwealth of Australia. https://disability.royalcommission.gov.au/publications/final-report; Jervis-Bardy, D. (2026, May 23).
Labor’sNDISoverhaulwillleaveparticipantsmore‘isolated’and‘segregated’,formerroyal
commissionerwarns. TheGuardian. https://www.theguardian.com/australia news/2026/may/23/albanese-government-ndis-legislation-cuts-changes-reform-australians-more isolated.
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33 Carers Australia, & Deloitte Access Economics. (2020, May). Thevalueofinformalcarein2020. Deloitte. https://www.deloitte.com/au/en/services/economics/perspectives/value-of-informal-care 2020.html, p. iii 34 Commonwealth of Australia. (2021). Budgetstrategyandoutlook:Budgetpaperno.1:2021–
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https://archive.budget.gov.au/2021-22/index.htm, p. 177 35 Australian Bureau of Statistics [ABS]. (2024, July 4). Disability,ageingandcarers,Australia: Summaryoffindings. https://www.abs.gov.au/statistics/health/disability/disability-ageing-and carers-australia-summary-findings/latest-release. 36 Yates, et al. 2021. 37 Gervais, R., & Millear, P. (2026). Women’s caring responsibilities as they age: Assessing the Sandwich Generation’s satisfaction with life and well-being. Community,Work&Family,29(2), 149–
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https://doi.org/10.1080/13668803.2024.2364093 38 Department of the Prime Minister and Cabinet, NDISReviewFinalReport, 2023, p. 192 39 Campanella, N., & Young, E. (2026, January 30). FamiliesfrayedbyNDIScutsbraceformore changeaheadofdefining2026. ABC News. https://www.abc.net.au/news/2026-01-30/families frayed-by-ndis-cuts-brace-for-more-change-in-2026/106269362 40 MacLennan, L. (2020, May 23). AnnMarieSmithwassurroundedbyprivilegebutdiedinsqualor— andherliferemainsamystery. ABC News. https://www.abc.net.au/news/2020-05-23/little-is known-about-the-life-of-ann-marie-smith/12275658 41 MacLennan, 2020. 42 Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. (2021,
May 31). WhathasbeenlearntsinceAnn-MarieSmith’sdeathtohelpprotectotherpeoplewith
disability[Media release]. https://disability.royalcommission.gov.au/news-and-media/media releases/what-has-been-learnt-ann-marie-smiths-death-help-protect-other-people-disability 43 Lechner-Scott, et al. 2021. 44 Basford Canales, S., & Jervis-Bardy, D. (2026, May 20). AustralianswithDownsyndromeamong thosetosuffermostfromproposedNDIScutstosocialactivities. The Guardian. https://www.theguardian.com/australia-news/2026/may/20/australians-with-downs syndrome-among-those-to-suffer-most-from-proposed-ndis-cuts-government-analysis-says. 45 van Toorn, G., & Dickinson, H. (2026, May 18). ThegovernmentplanstotightenNDIS eligibility.Here’swhat’slikelytochange. The Conversation. https://theconversation.com/the government-plans-to-tighten-ndis-eligibility-heres-whats-likely-to-change-283061. 46 Piantedosi, et al. 2025 47 See for example: Gadsden, T., Hallam, L., Carcel, C., Norton, R., Woodward, M., Chappell, L., & Downey, L. E. (2024). Theory of change for addressing sex and gender bias, invisibility and exclusion in Australian health and medical research, policy and practice. HealthResearchPolicyandSystems, 22, Article 86. https://doi.org/10.1186/s12961-024-01173-z; Carcel, C., Vassallo, A., Hallam, L., Shanthosh, J., Thompson, K., Halliday, L., Anderst, J., Smith, A. K., McKenzie, B. L., Newman, C. E., Bennett-Brook, K., Wainer, Z., Woodward, M., Norton, R., & Chappell, L. (2024). Policies on the collection, analysis, and reporting of sex and gender in Australian health and medical research: A mixed methods study. MedicalJournalofAustralia,221(7), 374–
- https://doi.org/10.5694/mja2.52435; Department of Health. (2025, October). Bridging the gender pain gap: The Inquiry into Women’s Pain Report 2025. Victorian Government. https://www.health.vic.gov.au/inquiry-into-womens-pain;
48 Australian Women’s Health Alliance. (2024, November). Thegenderedexperienceof
chronicconditions:Insights,challengesandopportunities(Women’s Health Hub Series 2024, No. 1). https://australianwomenshealth.org/wp-content/uploads/2024/11/Position-Paper-The-Gendered
Experience-of-Chronic-Conditions-1.pdf
49 Joint Standing Committee on the National Disability Insurance Scheme, 2026, Item 9 – Paragraph 32L(6)(a), p. 147.
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Submission 331
Gendered Risks of the NDIS Amendment Bill 2026
50 Cross, J. (2026, March 30). Over100MPsdemandurgentactiononagedcarereformsharming seniors. TheDailyTelegraph. https://www.dailytelegraph.com.au/health/wellbeing/ageing/over-100 mps-demand-urgent-action-on-aged-care-reforms-harming-seniors/news story/8eda27323b3823ca0279849bc1894d51; Payne, 2026. 51 See for example: Cross, 2026; Payne, 2026; van Toorn, G. (2026, April 24). NDISeligibilitywillbe basedon‘functionalcapacity’,notdiagnosticlabels.Butwhatdoesthatmean?The Conversation. https://theconversation.com/ndis-eligibility-will-be-based-on-functional-capacity not-diagnostic-labels-but-what-does-that-mean-281319; Lenzen, S. (2026, May 15). Australianswait 12monthsforagedcare:Andthelatestbudgetfundingisunlikelytochangethat. The Conversation. https://theconversation.com/australians-wait-12-months-for-aged-care-and-the latest-budget-funding-is-unlikely-to-change-that-282960;
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