Submission 3450 — Mrs Angela Batra-Mariani — NDIS Future Generations Bill | External submission

Submission to the Senate Community Affairs Legislation Committee

Inquiry: National Disability Insurance Scheme Amendment Securing the NDIS for Future

Generations) Bill 2026

Submitter: Angela Batra-Mariani

Capacity: Nominee for a family member; neurodivergent person; disability support worker and occupational therapist by background

Date: 31 May 2026

Introduction

Thank you for the opportunity to make a submission. I am writing from several overlapping perspectives. I am a nominee for a family member who is an NDIS participant. I am neurodivergent myself. I have also worked as a disability support worker and as an occupational therapist with NDIS participants. Across those roles, I have experienced and seen firsthand the stress participants, families, support workers and clinicians experience when trying to navigate the Scheme. I support reform of the NDIS. I want the Scheme to be sustainable, fair, less bureaucratic, easier to navigate, and better at identifying genuine waste, fraud and poor practice. I do not support reform that achieves apparent savings by reducing the rights, supports, review pathways or practical accessibility of disabled people and their families. My central concern is that the Bill risks making the Scheme more rigid, more automated, more compliance-driven and less human, while reducing rights of participants and shift ing more unpaid labour onto participants, nominees, families and informal supports. I am also concerned that the speed of this process makes meaningful consultation harder for the very people most affected by the Bill. A short consultation period is not neutral when people are already managing disability administration, care responsibilities, work, family life, neurodivergence, fatigue, crisis, or the ordinary pressure of trying to keep supports in place.

The NDIS is a human rights system, not only a budget line

The NDIS should be understood as part of Australia’s human rights infrastructure, in cluding Australia’s obligations under the United Nations Convention on the Rights of Per sons with Disabilities. It exists because people with disability have the right to dignity, autonomy, safety, participation, inclusion, and the supports required to live an ordinary life. Financial sustainability matters. But sustainability must not be defined only as reduc ing Scheme expenditure. A sustainable NDIS must also sustain the lives, relationships,

health, education, employment, community participation and informal support networks of the people who rely on it. If reforms reduce funded supports without considering what happens to the participant, their family, their nominee, their informal supports, and other public systems, then the cost has not disappeared. It has been shifted.

My experience as a nominee and informal support

As a nominee, my role is not just administrative. I help interpret the system, gather ev idence, communicate with providers, respond to requests, attend to deadlines, make sense of decisions, and advocate when something does not reflect the reality of my fam

ily member’s life. That work is often invisible.  It is not captured properly in a plan.  It is

not treated as a system cost. But it is real work, and it has real consequences. Providing informal support and acting as a nominee has affected my own work and study. I have missed paid work and missed university because care, advocacy, plan ning, evidence-gathering or crisis management had to come first. That is not unusual in families supporting disabled people. When the NDIS becomes harder to navigate, that pressure increases. The worst example in my own family was an urgent change of circumstances request that took several months to resolve. During that time my family member’s circumstances had changed, but the plan did not keep up. Funding ran out and we were left without the supports that were needed for months. I missed work repeatedly because informal support had to fill the gap. That kind of delay does not make support needs disappear. It transfers the cost to families, workplaces, study, health and informal care. Navigating the NDIS can feel like a part-time job, and it shouldn’t. Families should not have to be come case managers, legal advocates, administrators and evidence coordinators simply to access supports a person needs. My capacity to support my family member has decreased as other demands in my life have increased. Support coordination is vital in my family member’s life. Without a sup port coordinator, it would be incredibly difficult for us to coordinate the supports, services and practical steps needed for my family member to work towards their goals. Support coordination is not an optional extra for families like mine. It is often what makes the plan usable at all. This matters economically as well as personally. If a family member or nominee has to reduce work or study to provide unpaid care, coordinate supports, manage evidence or fight decisions, Australia loses that person’s contribution too. The cost is carried through lost income, lost tax, delayed education, reduced superannuation, poorer health, carer burnout and greater reliance on other systems. The Committee should not assess the cost of the NDIS by looking only at the participant’s plan. It must also consider the unpaid labour the Scheme depends on, and what happens when that labour becomes unsustainable.

Reform should reduce bureaucracy, not add to it

I strongly support reform that makes the NDIS less bureaucratic. One of the major inef ficiencies I have seen is the evidence process itself. Participants and families are often required to obtain long, expensive reports. Therapists may spend hours writing exten sive reports to justify supports that are clinically obvious, only for families to feel the reports were not read or were not understood. Participants may then be asked for more evidence, updated evidence, or differently worded evidence, even where their disability is permanent or their support needs are already well documented. The rhetoric that blames allied health professionals for waste is unfair when many clini cians are responding to the evidence burden the Scheme itself has created. Therapists write long reports because families are trying to provide enough detail to satisfy unclear and inconsistent NDIA expectations. If the system wants shorter, clearer and less expen sive evidence, it should set clearer evidence standards, trust concise clinical reasoning, and make decisions that properly engage with the material already provided. This bureaucracy also affects the workforce. Through my previous work as a disability support worker and occupational therapist, and through my current software work with

clinicians,  I regularly hear how distressed people are by NDIS administration.   I know

people who have left NDIS-related work, or chosen to work only in non-NDIS settings, because the bureaucracy of the NDIS is so difficult to work within. That is a loss to par ticipants and to the Scheme. Unnessecary bureaucracy is wasteful, it costs families money, time and energy, it con sumes therapy time that could be spent supporting participants, it burns out clinicians, it delays decisions, it also increases Scheme costs, because inefficient administration creates more reviews, appeals, complaints and crises. And Too many participants and families are being forced into stressful, inaccessible and expensive review pathways be fore decisions are corrected. My experience writing NDIS reports was one reason I co-founded a software company focussed on reducing the administrative burden of clinical documentation. I mention this because it reflects my direct experience of how much clinical time, family money and Scheme funding can be wasted by unclear and duplicated evidence requirements. I would be delighted if no therapist ever had to write a lengthy NDIS report again, because the Scheme had clearer evidence requirements, trusted concise clinical reasoning, and made better use of information already available. But the answer to bureaucracy is not to replace individualised evidence and human judge ment with blunt rules or blind automation. The better answer is to accept concise, struc tured, high-quality evidence from participants, families, nominees and qualified profes sionals, and to make decisions that properly engage with that evidence the first time.

Technology should support human judgement, not replace it

I am not opposed to technology or AI in the NDIS. I work in this space because I believe technology can reduce administrative burden, improve consistency, support better evidence and make systems easier to use. However, AI is not a replacement for humans. It is especially not a replacement for qualified people making decisions about disability, functional capacity, support needs, risk, safety, communication, family context, neurodivergence, fluctuating disability and participation. Automated tools may be useful for triage, document management, summarising evi dence, identifying missing information, improving accessibility, reducing duplication, and helping staff make more consistent decisions. But eligibility, planning, reassessment, suspension, funding and review decisions must remain subject to human judgement, human accountability and meaningful review. Any use of AI or automated decision-making in the NDIS should be transparent, ex plainable, auditable and accessible. Participants and nominees should know when technology has been used, what information was relied on, how to correct errors, and how to have a qualified human reconsider the decision.

Functional capacity must be understood in context

As an occupational therapist by background, I am concerned by any approach to func tional capacity that treats function as something that can be assessed in isolation from real life. Function is contextual. It depends on the person’s environment, supports, relationships, assistive technology, routines, communication needs, sensory load, fatigue, executive functioning, mental health, safety, transport, housing, and the reliability of informal sup ports. A person may appear capable in a narrow assessment context but be unable to perform the same activity safely, repeatedly or sustainably in daily life. A person may also func tion because supports are in place. Removing those supports can create the functional decline the system then treats as the person’s individual impairment. For neurodivergent people, people with psychosocial disability, people with fluctuating disability, and people who rely on nominees or family supports, a standardised or snap shot assessment can easily miss the real support need. Functional capacity assessments must therefore consider:

whether the person can perform tasks safely, consistently, repeatedly and sustain- ably;
the impact of fatigue, overwhelm, sensory load, anxiety, executive functioning and communication needs;

the role of informal supports and what happens when those supports are unavail- able or burnt out;
the person’s actual environment, not an idealised or artificial setting;
the risk of deterioration, isolation or crisis if supports are reduced. NDIS spending also supports the broader economy

NDIS funding should not be treated only as expenditure. It also supports economic partic ipation. At its best, the NDIS is an opportunity for Australia. It improves disabled people’s lives, supports families, creates employment, builds community inclusion and makes our society stronger. Disability can come for anyone, at any stage of life. Any of us may one day need disability support, or may have a child, parent, partner or sibling who does. A strong NDIS is not charity for a separate group of people; it is shared social infrastruc ture. In my own family, NDIS support means my family member is working towards moving into their own home. Without NDIS support, that would likely not be a realistic option. That is what the Scheme can make possible when it works well: not luxury, but ordinary adult life, independence, safety and a future. NDIS funding pays workers, allied health professionals, support coordinators, plan man agers, sole traders, small businesses and service providers. It enables some participants to work, study, volunteer or participate in community life. It also enables family members and carers to remain in paid work or education because they are not required to provide all support themselves. When supports are reduced, those economic benefits can be reduced too. The partici pant may lose capacity, routine or independence. Informal supports may have to reduce paid work or study. Providers may lose viability. Health, housing, justice, education and crisis systems may absorb costs that were previously prevented by timely disability sup port. Any reform that increases the burden on informal supports must account for that cost honestly.

Social and community participation is not optional

I am concerned by any reform that treats social and community participation as discre tionary or less important than other supports. For many people with disability, participation supports are not luxuries. They are how people maintain routine, emotional regulation, safety, communication, confidence, rela tionships, independence, and connection to ordinary life. They can also prevent decline, isolation, family burnout and crisis.

The Committee should ensure that social and community participation supports are pro tected where they are necessary for a person’s wellbeing, development, safety, skill building, mental health, communication, independence or family stability. Public rhetoric about the NDIS also matters. The Government should do more to stand by the purpose of the Scheme and to correct misleading public narratives about partic ipants receiving support for ordinary activities such as haircuts, movies or community outings. The issue is not whether a disabled person should be allowed to do ordinary things. Of course they should. The relevant question is whether the person requires disability-related support to access those ordinary parts of life safely and with dignity. People with disability have the same right as anyone else to participate in everyday life.

Fraud, registration and choice and control

I support strong action against fraud, exploitation, overcharging and deliberate misuse of public funds. However, registration status alone is not a guarantee of quality or integrity. Poor practice, overcharging or exploitation can occur in registered and unregistered set tings. Mandatory registration by itself will not solve fraud if it simply makes the market harder for small, ethical providers while leaving larger providers with the resources to absorb compliance costs. If registration becomes mandatory, it must be accessible, proportionate and affordable for sole traders and small providers. Many participants rely on individual support work ers, sole traders and small allied health providers because those people know them well, communicate in ways that work for them, or have lived and professional experience that larger providers may not offer. If registration is too expensive or complex, it risks pushing experienced sole traders out of the Scheme and concentrating the market among large providers who can afford compliance infrastructure. That would reduce choice and control for participants and reduce opportunities for peo ple with disability experience, family experience or community-based expertise to work in the Scheme. Integrity reforms should target exploitation without narrowing the provider market so much that participants lose the relationships and supports that make their lives work.

Recommendations

I ask the Committee to recommend that:

The Bill not proceed in its current form without further genuine, accessible consul- tation with disabled people, families, nominees, carers, clinicians, providers and advocates.

Any reform be assessed against Australia’s human rights obligations, including the rights of people with disability to dignity, autonomy, participation, accessibility, equality and non-discrimination.
Functional capacity be defined and assessed in real-world context, including envi- ronment, supports, assistive technology, communication needs, sensory load, fa tigue, executive functioning, fluctuating disability, risk, and informal support sus tainability.
The NDIA reduce administrative waste by accepting concise, structured, high- quality evidence and avoiding repeated requests for long reports where sufficient evidence already exists.
The NDIA give proper weight to evidence from participants, nominees, families, treating clinicians, allied health professionals and other qualified people who un derstand the person’s real life.
AI and automated tools be used only to support accessibility, efficiency and con- sistency, not to replace qualified human decision-making about eligibility, planning, reassessment, suspension, funding or review.
Any automated or AI-supported process be transparent, explainable, auditable, ac- cessible and subject to meaningful human review.
Economic modelling of NDIS reform include the cost of unpaid care, missed work, missed education, lost tax revenue, carer burnout, reduced superannuation, health impacts, and cost-shifting to other public systems.
Social and community participation supports be protected where they are neces- sary to maintain safety, health, wellbeing, independence, development, communi cation, routine, family stability or community connection.
Compliance and anti-fraud measures focus on exploitative providers and deliberate wrongdoing, while protecting participants, families and nominees acting in good faith from punitive or inaccessible processes.
Any provider registration requirements be risk-proportionate, affordable and acces- sible for sole traders and small providers, so that fraud prevention does not unin tentionally reduce participant choice and control or concentrate the market among large providers.
Support coordination be protected where it is necessary to help participants and families implement plans, connect with services, navigate complexity, reduce nom inee burden and work towards participant goals.

Closing

I support reform of the NDIS as I want the Scheme to be sustainable with less bureau cracy, clearer evidence, better technology, more consistent decisions and stronger ac

tion against poor practice. Reform should not put participants at risk. It should not shift the real cost of support onto families, nominees and unpaid carers. It should not treat AI or standardised tools as a substitute for qualified human judgement. And it must not define sustainability so narrowly that the Scheme saves money only by creating greater costs elsewhere. A better NDIS is possible. It should be simpler, accessible, evidence-informed, and more rights-based. That is the reform I ask the Committee to pursue.