Submission 367
National •~L• The equitable, healthy and sustainable Rural Health access for rural, regional and remotei,~ • • ,, • Alliance communities across Australia29 May 2026
Senator Dorinda Cox
Committee Chair
Senate Standing Committee on Community Affairs - Legislation Committee
PO Box 6100
Parliament House
Canberra ACT 2600
Email: community.affairs.sen@aph.gov.au
Submission to the Senate Community Affairs Legislation Committee on the
Dear Senator Cox and Legislation Committee
The National Rural Health Alliance (the Alliance) welcomes the opportunity to respond to the Senate Standing
Committee on Community Affairs - Legislation Committee Inquiry into the National Disability Insurance Scheme
Amendment (Securing the NDIS for Future Generations) Bill 2026 (the Bill), with a focus on rural equity, psychosocial supports and thin/failed market safeguards for our regional, rural and remote (hereafter rural) communities.
The Alliance is the peak body for regional, rural and remote health in Australia, comprising 56 member organisations which include healthcare, disability and ageing professionals, service providers, health and medical educators and trainers, researchers, medical and health practitioner students, the Aboriginal and Torres Strait Islander health sector and organisations that deliver care for rural and remote Australians.
Our vision is for healthy and sustainable rural communities, which make up the more than 7.4 million people residing outside our major cities, or approximately 30% of the Australian population. We are focused on advancing rural health reform to achieve equitable and flexible health funding and care access equivalent to that of urban per capita spending. Equitable healthcare access and health outcomes should not be determined by a person’s post code.
The Alliance has outlined recommended amendments and implementation safeguards needed to prevent rural, regional and remote Australians with disability, including psychosocial disability, being left with less access and less of the allocation of funding, less choice, shorter life spans, greater burden on carers in particular women and greater administrative burden.
Summary of Key Issues of Concern for the National Rural Health Alliance
The Alliance supports a sustainable National Disability Insurance Scheme (NDIS). Sustainability, however, cannot be achieved by shifting cost, complexity and risk onto people who already face limited service markets. In addition, reviews have been noticeably clear about rural people receiving inequitable disability and health funding and services resulting in major disparities in care and support options, and resulting reductions in safety,
T 02 6285 4660 E nrha@ruralhealth.org.au W ruralhealth.org.au NRHAlliancePO Box 475 Curtin ACT 2605
ABN 68 480 848 412 ACN 620 779 606 ARBN 620 779 606Submission 367
dignity, and the opportunity to thrive for many rural Australians with as disability.1 Further, there have already been reductions to travel allowances for allied health providers and this impacts rural providers and rural people with a disability disproportionately.2
The rural equity test for the Bill is simple: no person with a disability living in Australia should lose fundamental access to support because the legislation assumes the existence of a functioning service market that is not available in their community.
The Bill proposes major changes to access, functional capacity assessment, support determinations, plan renewals, unscheduled reassessments, permanence criteria, plan, suspension, and support budgets. In metropolitan areas, some changes may be mitigated by provider density, advocacy capacity, transport, and market alternatives. In rural, regional, and remote Australia, these mitigations are often absent. This results in a disproportionate increase in the risk profile the associated with implementing these legislative changes in rural Australia.
The proposed changes raise concerns about fairness, safety, and equity in how people with disability access and sustain supports. Alliance members have expressed concerns that several provisions would shift significant decision-making power to a Minister or Agency without adequate safeguards, transparency, or accountability. This creates a risk that funding decisions such as setting caps, redefining “reasonable and necessary” supports, or imposing broad determinations could override individual needs, inequity amongst the Australian public for political gain and undermine the principle that supports should be tailored to enable participation, independence, and long-term wellbeing. These issues would be exacerbated for people with a disability who live in rural Australia.
A further concern is that the proposals place undue weight on narrow or inaccessible forms of evidence and service availability, which risks entrenching inequity. Requiring participants to exhaust all “appropriate” treatments, or privileging peer-reviewed research over lived experience and other forms of evidence, does not reflect the realities of disability support. This is particularly relevant in rural, remote, or underserved areas where services may be unavailable, unaffordable, or unsupported by a strong research base. Similarly, reliance on alternative support systems assumes these are equivalent and accessible, which is often not the case, particularly in thin markets where service options are limited or non-existent.
The risk is not theoretical: reform without funded alternatives creates a service cliff.
The Alliance has received feedback concerning the unintended consequence of fragmentation in care pathways if the Minister is granted the power to make support determinations that may result in participants receiving funding below what has been assessed as reasonable and necessary.
The National Rural Health Alliance therefore urges the Senate Committee to recommend that the Bill not proceed in its current form unless rural safeguards, psychosocial support funding, transparent data obligations, and thin-market commissioning mechanisms are built into the legislation or binding implementation instruments.
1 See Joint Standing Committee on the National Disability Insurance Scheme Inquiry into NDIS participant experience in rural, regional, and remote Australia (2024 -2025); The National Rural Health Alliance report: The Forgotten Health Spend: A Report on the Expenditure Deficit in Rural Australia (2025). 2 National Rural Health Alliance (June 2025) Media Release: Proposed NDIS travel allowance cuts, a blow to rural providers and people with a disability (available at ruralhealth.org.au). 2
Submission 367
Why the Senate Committee must apply a rural equity lens
The Alliance holds concern that the Bill is being considered on an accelerated timetable. This creates a high governance risk for rural Australians because the practical effect of NDIS reform will be determined not only by eligibility language, but by the actual availability of providers, transport, allied health workforce, advocacy, digital access, and psychosocial supports in local communities. The Alliance has prepared the table below to illustrate the nuances of rural equity issues and the importance of the Senate Committee applying a rural equity lens.
Rural equity issue Reality on the ground Risk under the Bill
Service market failure Thin markets mean some participants Budget reductions or narrower accesshave funding, but no provider, or only rules may reduce nominal expenditure one provider with limited capacity. while increasing unmet need, hospital reliance, carer strain, and crisis presentations.
Travel and transport Long distances and lack of accessible Support that is “available” in a city may
burden transport raise the cost and time be functionally unavailable for a remoterequired to access support. participant.
Shared workforce Allied health, disability, aged care, and Reforms in one system can destabilise
across sectors primary care draw from the same the others unless workforce planning islimited rural workforce. aligned.
Information and NDIS access and reassessment are Tighter reassessment and record-
advocacy deficit harder where there is limited local keeping rules may disproportionatelynavigation, legal advice, and advocacy. exclude rural participants.
Psychosocial support A large national unmet need exists Moving people toward “foundational” or
gap outside the NDIS, with poor granularity mainstream support before thoseon rural need. supports exist will create a service cliff.
Assessment of key Bill elements through a rural lens
The following table further analyses critical components of the Bill, outlining potential benefits, risks and safeguards which must be considered to mitigate potential implementation concerns.
Bill element Potential benefit Rural risk Required safeguard
Functional Standardised, High risk if tools are not validated Require independent rural
capacity access evidence-based in rural, remote, First Nations and validation; provide specific
test assessment may culturally diverse contexts. funding for assessment-
improve consistency. Additional potential risk if related evidence; allowassessment access requires telehealth plus outreach; specific allied health evidence embed cultural safety and that may be unavailable in some communication supports. communities due to ongoing limited workforce availability.
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Bill element Potential benefit Rural risk Required safeguard
Limits on May reduce Rural participants may Define rural provider
unscheduled plan administrative churn. experience sudden provider loss, withdrawal, transport
reassessments carer collapse, floods, fires, collapse, disaster impact, andrelocation, or workforce carer burnout as valid withdrawal which all impact reassessment triggers. perception of plan usage and do not fit narrow criteria quickly enough.
Support May target areas of Community participation and No reduction in MMM4-7
determinations over-spend or capacity-building are not until substitute support exists
reducing groups inconsistent use. discretionary extras particularly and local market adequacy is
of supports in rural areas; they prevent independently verified.isolation, crisis, and premature institutional reliance.
Plan end dates Could improve Underspending in rural plans Exclude demonstrable thin-
and no carry-over budget discipline. often reflects lack of providers, market underspend from
of unspent funds not lack of need. Removing negative assumptions; allowunspent funds penalises thin- protected carry-over or market failure. alternative commissioning.
Plan suspension May assist integrity Participants with poor Require multiple accessible
after failed and administration. connectivity, unstable housing, contact channels, trusted
contact mental illness, cognitive local intermediary checks anddisability, family violence, or an independent rural remote travel may be wrongly hardship safeguard before suspended. suspension.
Permanence and Clarification can For psychosocial disability and Do not treat unavailable rural
treatment improve scheme complex conditions, treatment treatment as refusal or
requirements boundaries. access is uneven, and failure; require evidence of“appropriate treatment” may not practical access, not be available locally. theoretical availability.
Support needs Potential for fairer If environmental factors are Mandate rural environmental
assessment / new planning if well- underweighted, rural people will loadings: travel, workforce
framework designed. get plans that look fair on paper scarcity, provider wait time,
planning but fail in practice. cultural safety, transport, anddisaster risk.
Psychosocial disability and community support: the service cliff risk
The Alliance has noted commentary outlined in Croakey Media raising concerns from disability advocates and mental health researchers that the NDIS Impact Analysis is a blunt instrument unless read against lived experience, thin markets, psychosocial support gaps and implementation realities. 3 The Senate Committee should treat these concerns as a warning signal: reforms focused on budget control can increase downstream cost if people lose early, practical and community-based supports.
The Commonwealth-funded psychosocial unmet-need analysis reveals very concerning statistics. It estimated that, in 2022-23, 647,300 people aged 12-64 with moderate or severe mental illness required psychosocial
3 Croakey, NDIS Impact Analysis a “blunt instrument” and Bill will cause harms if not amended, May 2026.
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support. Of this total, there were 493,640 people who were not receiving psychosocial support. Among people aged 65 and over, 133,270 were not receiving needed psychosocial support. For people aged between 12-64 who experience severe mental illness, the sensitivity analysis estimated with high confidence that between 214,800 and 238,7 people required but were not receiving psychosocial support.4 This also highlights potential unintended consequences of limiting services and creating fragmentation related to transitioning people from NDIS to Aged Care packages, which is out of scope of this Bill.
The Alliance notes that these figures represent a national overview, and there is value in aggregating the data via rurality to strengthen the understanding of how rural areas are impacted by limited psychosocial support services.
National Rural Health Alliance Recommendations to the Senate Community Affairs Legislation
Committee
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Amend the Bill to require a Rural and Remote NDIS Equity Impact Statement before each major rule; support determination, access instrument or assessment tool is commenced. The Statement should assess impacts by Modified Monash Model (MMM) category, First Nations status (where appropriate), disability cohort, age, psychosocial disability, market adequacy, workforce, provider availability, and transport burden.
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Insert a no-detriment safeguard for participants in MMM 4-7 areas where alternative support or providers are not demonstrably available.
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Delay support budget reductions for social, civic, community participation and capacity-building activities in thin markets until locally commissioned alternatives are operational and independently verified. Community connection is a preventive health intervention in rural areas, not a luxury line item.
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Fund a national rural psychosocial support guarantee, including non-clinical community psychosocial supports for people with severe and moderate mental illness, who are not NDIS participants and transitional protection for people with psychosocial disability currently relying on NDIS supports. This should include transparent Commonwealth and State/Territory responsibilities and rural commissioning targets and rural loadings.
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Legislate rural data transparency: NDIS participation, plan utilisation, provider availability, wait times, reassessment outcomes, appeals, suspensions and market gaps to be reported by remoteness, MMM category (not state-level averages), First Nations status (where appropriate) and disability type, with privacy protections.
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Create a Rural Thin /Failed Market Commissioning Fund that allows block, blended, outreach, salaried and pooled workforce models rather than assuming individualised market purchasing can solve supply failure, or funding can be saved or redistributed to urban centres. Commissioning should include local non-clinical support through community organisations, Aboriginal Community Controlled Health Organisations, rural health services, peer organisations and outreach models.
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Require NDIA to co-design implementation with rural people with disability, First Nations communities, local providers, health services, PHNs, local government and rural peak bodies before rural implementation. The Alliance is well placed to support NDIA in this action.
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Do not penalise rural underspend caused by provider shortages. Plan underspends should be interpreted through a thin-market lens. Where participants cannot use funds because there are no providers available, the remedy should be market stewardship or alternative commissioning, not budget reductions, or a finding of lower need.
4Health Policy Analysis Pty Ltd (2024) “Analysis of unmet need for psychosocial supports outside the NDIS Final Report, August 2024. 5
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Make functional capacity assessment rural-proof. Assessments tools must be validated for rural and remote conditions, First Nations cultural contexts, psychosocial disability, and fluctuating conditions. The Federal Government must provide accountability and fund the evidence-gathering burden, including allied health reports, travel, telehealth, and outreach.
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Build a rural disability navigation workforce. Fund trusted local navigators embedded in rural health, community, First Nations, and disability organisations to help people understand access, reassessment, claims, records, appeals, and service options.
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Embed cross-sector workforce planning. The NDIS, health, aged care, mental health, and primary care reforms must be planned together in rural areas because they rely on the same limited workforce. There should be a joint rural workforce implementation plan across Government portfolios and States/Territories.
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Create an independent rural oversight mechanism. This could take the form of an independent rural NDIS implementation advisory group which should report publicly to Ministers and Parliament every six months for the first three years of reform implementation.
Implementation roadmap requested of Government
To assist the Committee, the Alliance suggests the following timeframes for implementation of the key recommendations and directions proposed in this submission:
Timeframe Action
0-180 days Publish rural implementation risk register; establish rural NDIS advisory group; release draft Rural Equity Impact Statement template; identify high-risk MMM4-7 locations; pause any support budget reset in thin markets. 6-12 months Map provider availability, plan utilisation and unmet demand by remoteness; design psychosocial support guarantee; fund rural navigators; commence co-design with First Nations and rural disability organisations. 1-2 years Launch Rural Thin Market Commissioning Fund; commission psychosocial supports in priority rural regions; publish baseline rural NDIS equity dashboard; validate assessment tools in rural settings. 2-3 years Independent evaluation of rural safeguards; adjust funding loadings; report on plan utilisation, reassessment outcomes, appeal rates, suspensions, and provider supply; scale successful models nationally, review workforce development and status.
Risks - if the Bill proceeds without amendment
There are inherent risks if the Bill is passed in its current form. The following summarises some of these risks, consequences, and mitigation strategies:
Risk rating Risk Consequence Mitigation
Red - high Support reductions occur Loss of community Legislate no-detriment
before alternatives exist participation, increased safeguard and stagedisolation, carer burden, commencement after local inequity of service delivery, adequacy test. deterioration, and crisis presentations.
Red - high Psychosocial support cliff People with mental illness Fund rural psychosocialfall between the cracks of a guarantees before access or fragmented NDIS, mental support restrictions affect this health, and community cohort. system. 6
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Red - high Thin/failed market Plans are reduced because Mandatory underspend
underspend misread as support cannot be reason codes and thin/failed-
lower need, funding shift purchased locally. market exception process.to urban Australia Ensuring funding allocation continues. Lack of does not move to urban expenditure seen as a cost- centres or as a saving saving opportunity by opportunity, by ignoring Government, at expense to market or policy failure members of the community
Amber - Assessment tools Functional capacity decisions Independent rural validation
medium/high underweight for rural and fail to capture travel, and environmental loading.remote context provider scarcity, cultural safety, and environmental barriers.
Amber - Plan suspension due to Participants with poor Local intermediary check and
medium/high failed context and contract connectivity or complex hardship review beforecircumstances lose access suspension. unfairly. Review flexibility to deliver like care
Amber – Provider consolidation, (or Plan management or Rural market impact review
medium lack of consideration to support co-ordination and exemptions where
grow local workforce via reforms shrink rural provider provider choice is limited or
health workforce base. non-existent. Reviews showstrategies) reduces local reason for lack of market and choice longer-term workforce growth projections.
Green - Commissioning enables Fund local capacity building Use block/blended funding
opportunity better local models activities to improve rural and local governance to buildaccess rural service capacity.
Conclusion:
The Alliance urges the Senate Committee to avoid a false trade-off between sustainability and equity. The NDIS must be financially sustainable, but it must also be accessible. Rural Australians have already received less healthcare and disability access than urban population, resulting in less care, earlier deaths, and elevated stress. People with disabilities in rural Australia face thinner or no markets, fewer providers, higher travel costs, worse health care and health status and more complex, inflexible, and fragmented navigation. Reform that assumes a metropolitan service base will widen inequity and is not a true cost-saving opportunity.
The Senate Committee can convert the Bill from a budget-control instrument into a genuine stewardship framework. This requires enforceable rural safeguards and mechanisms to manage appropriate utilisation, and ensure funded psychosocial support, transparent data and commissioning tools that build supply where markets have failed.
These changes to short, medium, and long-term supply can be dealt with in conjunction with Department of Health, Disability and Ageing health and medical workforce plans, strategies, and action. Indeed, in rural Australia many clinicians already work across health, aged care, and disability. 7
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Without those changes, the Bill risks moving costs to other overburdened areas. At a systems-level, this would move from the NDIS ledger to hospitals (when rural hospitals are already underfunded). At a personal level, this shift would greatly impact carers, families, communities and above all, people with disabilities themselves.
I thank you Senator Cox and Legislation Committee for the Inquiry and would be pleased to provide further information on any of the information contained in this submission if required.
Yours sincerely,
Susi Tegen
Chief Executive
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References used in the development of this Submission
Australian Government. Independent Review into the NDIS. Foundational support for all people with disability fact sheet. 7 December 2023. https://www.ndisreview.gov.au/resources/fact-sheet/foundational-supports-all people-disability
Australian Institute of Health and Welfare. People with disability in Australia 2024: Access to health services. Published 23 April 2024. https://www.aihw.gov.au/reports/disability/people-with-disability-in australia/contents/health/access-to-health-services.
Australian Institute of Health and Welfare. Rural and remote Australians: Overview. Updated 20 November 2025. https://www.aihw.gov.au/reports-data/population-groups/rural-remote-australians/overview
Health Policy Analysis. Analysis of unmet need for psychosocial supports outside of the National Disability Insurance Scheme: Final Report. Prepared for the Department of Health and Aged Care, August 2024. https://www.health.gov.au/sites/default/files/2024-08/analysis-of-unmet-need-for-psychosocial-supports outside-of-the-national-disability-insurance-scheme-final-report.pdf
National Rural Health Alliance. Disability and access to the NDIS in rural Australia. Fact sheet. February 2023. https://www.ruralhealth.org.au/wp-content/uploads/2024/05/nrha-disability-factsheet-feb-2023-final.pdf
National Rural Health Alliance. Submission to the Joint Standing Committee on the National Disability Insurance Scheme inquiry into the capability and culture of the National Disability Insurance Agency. 12 October 2022. https://www.ruralhealth.org.au/wp-content/uploads/2024/11/national-rural-health-alliance-submission-inquiry capability-and-culture-ndia.pdf
National Rural Health Alliance and Office of the National Rural Health Commissioner. Submission to the Joint
Standing Committee on the National Disability Insurance Scheme Inquiry into the NDIS participant experience in rural, regional and remote Australia. March 2024. https://www.ruralhealth.org.au/policy/submission/joint standing-committee-on-the-national-disability-insurance-scheme-inquiry-ndis-participant-experience-in-rural regional-and-remote-australia/
National Rural Health Alliance, with NOUS Group The Forgotten Health Spend: A Report on the Expenditure Deficit in Rural Australia. 2025 https://www.ruralhealth.org.au/the-forgotten-health-spend-report/
Office of Impact Analysis, Department of the Prime Minister, and Cabinet. National Disability Insurance Scheme
Reforms. Published 14 May 2026. https://oia.pmc.gov.au/published-impact-analyses-and-reports/national disability-insurance-scheme-reforms
Croakey Health Media. NDIS Budget reforms fail at first step on First Nations, rural and remote, psychosocial supports. May 2026. https://www.croakey.org/ndis-budget-reforms-fail-at-first-step-on-first-nations-rural-and remote-psychosocial-supports/
Croakey Health Media. NDIS Impact Analysis is a “blunt instrument” and Bill will cause harm if not amended. May
- https://www.croakey.org/ndis-impact-analysis-a-blunt-instrument-and-bill-will-cause-harms-if-not- amended/
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