Letter from aBehaviour Support Practitioner regardingNDIS Funding

I am writing as a Behaviour Support Practitioner (BSP) working directly with NDIS participants with complex support needs. Much of my caseload consists of participants whose behaviours of concern emerge in part because they do not receive the level of practical support required to safely participate in daily life.

In my professional experience, behaviours of concern are frequently the result of chronic under-support1. For example, I work with a participant funded at a 1:3 support ratio who requires substantially more individualised support to remain safe and regulated. This participant requires:

assistance to follow visual schedules step-by-step;
assistance to start and continue tasks;
prompting delivered at a pace appropriate to their cognitive processing;
proactive emotional regulation support; and
individualised assistance to safely access the community.

Without these supports, the participant engages in self-harm, aggression, emotional dysregulation, and other behaviours of concern2.

Similarly, I have supported participants funded in shared support arrangements with wheelchair users, where support ratios made it impossible to safely access activities such as swimming, walking, or community outings, leaving the participant essentially housebound. We were able to advocate for a review of funding, which enabled increased community participation support. As a result, the participant was able to access the community more regularly, exercise choice in the activities she could do, and experienced a reduction in behaviours of concern due to the significant improvement in their quality of life. Under the changes proposed in this Bill, I believe that this would not have been possible, and she is likely to have her funding cut again, increasing her behaviours of concern and decreasing her quality of life.

Even the highest quality, evidence-based, person-centred Behaviour Support Plan cannot succeed if participants do not have sufficient funding to implement the recommendations. Behaviour support cannot compensate for unmet care needs. There is no shortcut around the level of support a person genuinely requires.

I am deeply concerned that reducing participant funding will lead to increased behaviours of concern, greater use of restrictive practices, more injuries to participants and staff, increased hospital presentations, and ultimately preventable, tragic deaths.

The Disability Royal Commission

The Disability Royal Commission recognised that behaviours of concern are often not simply “within” the person, but arise in contexts where people lack choice, control, communication support and appropriate individualised assistance. In relation to group homes, the Commission noted that “there is a link between lack of choice and control, unmet needs and the emergence or escalation of behaviours of concern”

This is directly relevant to the proposed reforms. When participants are funded at ratios that do not meet their functional, communication, sensory, mobility or emotional regulation needs, those unmet needs become the setting conditions for distress and behaviours of concern. In practice, this increases the likelihood that providers will respond through restrictive practices, including chemical restraint, rather than through proactive, person-centred support.

The Royal Commission also found that psychotropic medication is over-prescribed to people with cognitive disability to manage so-called “behaviours of concern”, and in too many cases is used as chemical restraint. This should be a warning against reforms that knowingly increase under-support. If participants lose access to the staffing ratios and community participation supports they require, the likely result is not reduced need. It is increased distress, increased risk, increased restrictive practices, and increased harm.

Australia cannot credibly aim to reduce restrictive practices while simultaneously introducing policy settings that make restrictive practices more likely. Reducing funding for people with complex support needs will not remove those needs. It will simply make them harder to meet safely.

Ironically, as a BSP, these reforms will increase demand for my profession due to worsening participant distress and risk. However, I do not believe this represents good policy or ethical practice.

I am particularly concerned about reforms that reduce Social and Community Participation (SCCP) funding. Limiting these supports risks leaving people housebound and significantly restricts their choice and control over how they participate in community life.

The Government’s own analysis acknowledges this concern. The May 2026 National Disability Insurance Scheme Reforms Impact Analysis stated: “NDIS participants … with a primary disability of visual impairment, Down syndrome, and Intellectual Disability may be more affected by this change. For these cohorts, total committed supports for SCCP budgets are higher than the overall Scheme proportion.”

These cohorts often require funded support workers to safely access the community.

Reducing this funding does not reduce their support needs; it simply removes their ability to participate safely.

Equal rights are not upheld where a participant’s funding restrictions mean they can only leave the house if all members of a shared support ratio agree to undertake the same activity. This significantly undermines participant choice and control.

These reforms also conflict with Article 19 of the United Nations Convention on the Rights of Persons with Disabilities (CRPD), which recognises the equal right of people with disability to live and participate in the community and requires States to ensure access to supports necessary to prevent isolation and segregation.

Limiting Participant-Requested Plan Reassessments

I am deeply concerned about proposals to limit participant-requested plan reassessments.

If a participant communicates that their support arrangements are unsafe or ineffective, striking their ability to seek reassessment is both dangerous and unjust.

Increases in funding following reassessment often indicate that the original plan did not adequately meet the participant’s needs. Preventing participants from challenging or reviewing these decisions risks entrenching unsafe or inadequate supports, and limits their access to justice.

I am also concerned by rhetoric framing the Administrative Review Tribunal (ART) as a “problem” rather than recognising its role as an essential safeguard that allows participants to challenge incorrect decisions. A tribunal overturning NDIA decisions should not be viewed as justification for restricting participant rights or limiting oversight, when it is someone’s legal avenue to challenge unfair or inadequate decisions.

Ministerial Power to Reduce Funding for Categories of Supports

I oppose proposals that would allow the Minister to reduce funding across categories of supports. There is no evidence demonstrating that reducing disability support funding improves participant wellbeing or outcomes.

This proposal would allow funding decisions to be shaped by fiscal priorities rather than individual participant needs. It creates the risk that funding could be reduced across entire groups of participants based on broad categorisation rather than functional need or evidence-based assessment. This undermines the individualised nature of the NDIS and weakens participant choice and control.

Early Intervention and “Thriving Kids”

I am particularly concerned about reductions to individualised early intervention supports for children. Article 7 of the CRPD states that the best interests of the child must be a primary consideration in all actions concerning children with disabilities.

Individualised, evidence-based early intervention is one of the strongest predictors of

improved long-term outcomes for children with disability45. Reducing access to 1:1 supports may result in children developing greater support needs over time because they did not receive intervention at the stage when it was most effective.

These reforms risk worsening long-term outcomes while also increasing future system costs.

Functional Capacity Assessments and the I-CAN Tool

I welcome greater transparency and consistency in how support needs are assessed. However, I have significant concerns regarding the proposed assessment process.

A one-size-fits-all assessment model risks overlooking critical contextual factors that are highly relevant to participant safety, wellbeing, and functioning.

I am particularly concerned that:

participants may not have meaningful rights to appeal assessment outcomes;
professionals and support people who know the participant well may be excluded from decision-making; and
assessors are not required to have allied health qualifications.

It is alarming that the NDIA has proposed that assessors using the I-CAN tool may not require allied health backgrounds.

The I-CAN tool has not been adequately validated across many disability populations, including:

Autism Spectrum Disorder;
psychosocial disability;
traumatic brain injury; and
co-occurring disabilities.

Rolling out an assessment tool across the entire adult NDIS population without sufficient validation across these groups would be irresponsible and harmful.

Automated Decision-Making

I am concerned about proposals permitting automated administrative decision-making within the NDIS.

Given the significant harms caused by Robodebt, it is alarming that automated decision-making is again being considered in a system supporting vulnerable Australians

who already have barriers to accessible appeals processes, alongside the proposed

limitations to participant appeals.

NDIS funding decisions have profound impacts on safety, health, autonomy, and quality of life. These decisions require nuanced human judgement and cannot ethically or safely be reduced to automated processes.

Reliance on Mainstream Supports The proposed reforms appear to assume that mainstream systems can absorb participants who lose access to NDIS supports. However, autistic people and people with intellectual disability already experience substantial barriers to healthcare access, communication, service navigation, and equitable treatment within mainstream systems.6

Reducing NDIS supports without having a robust mainstream system that is accessible and caters to their unique support and healthcare needs risks abandoning people into systems that are already failing them.

The Government’s own analysis acknowledges that inadequate mainstream supports may result in people later re-entering the NDIS with higher and more complex support needs.

Fraud and Provider Accountability I support stronger measures targeting fraud and improving provider accountability.

I support: - encouraging provider registration; - improving quality and safeguarding standards; and - increasing documentation requirements, such as mandatory progress notes following support delivery.

Fraudulent providers should be the focus of reform. However, it is deeply concerning that reforms introduced in response to fraud disproportionately impact people with disability rather than squarely targeting fraudulent operators themselves.

People with disability should not bear the burden of systemic failures caused by unethical providers.

The NDIS was established to uphold dignity, autonomy, inclusion, and human rights. Reforms that reduce support access, restrict review mechanisms, and diminish participant choice fundamentally undermine those principles.