Introduction and Submission Objection

I am writing this submission as the primary informal support person and administrator

for an NDIS participant with severe intellectual disability, Level 3 Autism Spectrum

Disorder with a Pathological Demand Avoidance (PDA) profile, moderate anxiety, and

PTSD-related characteristics.

In my role supporting him, I manage much of the administrative and practical

structure surrounding his care, including NDIS administration, support coordination

tasks, documentation, provider communication, business and employment-related

tasks, and the day-to-day systems required to maintain stability and safety.

I strongly object to the proposed National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026 and the associated 2026–27

Federal Budget measures.

While these reforms are being presented as measures to “secure the future” of the

NDIS, the practical impact on participants with high and complex support needs will

be devastating. The proposed changes risk dismantling the carefully structured

supports that currently prevent crisis, institutionalisation, carer collapse, and severe

behavioural escalation.

From my direct experience supporting this participant, I believe these reforms

fundamentally misunderstand the realities of complex neurodivergent disability nsupport. They reduce nuanced human support systems into cost-saving exercises and standardised benchmarks that fail to capture real-world functioning.

Current Supports and Why They Matter:

The participant’s current NDIS plan was built upon comprehensive Functional Capacity Assessments, specialist reports, behavioural evidence, and years of documented professional involvement.

This plan is not excessive. It is stabilising.

The existing supports allow him to:

• remain safely at home with family support,
• participate in the community,
• regulate behavioural escalation,
• avoid institutional settings,
• maintain trusted support worker relationships,
• reduce mental health deterioration,
• and prevent crisis-level interventions.

Without these supports, the likely outcome is not increased independence or reduced government spending. The likely outcome is family burnout, emergency service involvement, psychiatric escalation, and eventual reliance on far more expensive state-based systems.

The Threat of Exclusion from the Insurance Scheme, and Continued Supports:

The proposed reforms aim to significantly reduce participant numbers and move away from specialist diagnosis-based evidence toward standardised functional assessments.

This creates serious risks for participants with complex Autism Spectrum Disorder profiles, intellectual disability, and PDA presentations.

From my lived experience supporting him, standardised assessments frequently fail to capture his actual support needs. In calm or structured settings, he may appear superficially capable for short periods. However, once pressure, unpredictability, demands, sensory stress, or unfamiliar expectations are introduced, his functioning can rapidly deteriorate into shutdown, distress, refusal, or behavioural escalation.

These presentations are not behavioural choices. They are neurological responses.

A standardised assessment process that ignores context, anxiety, environmental

tiggers, and support dependency risks incorrectly determining that he no longer nifies for essential support.

If removed from the NDIS or significantly reduced in support eligibility, there is no realistic alternative system capable of meeting his needs.

Dismantling Specialist Behaviour Support: The participant’s current plan includes specialist behavioural support funding that allows qualified practitioners to:

• develop behavioural support plans,
• train support workers,
• train family carers,
• identify triggers,
• reduce risk,
• and implement preventative strategies.

These supports are not optional extras.

For participants with severe anxiety, intellectual disability, and PDA-related presentations, proactive behavioural intervention is often the only thing preventing serious escalation.

Reducing access to behavioural support under stricter “reasonable and necessary” interpretations would create significant safety risks for:

• the participant,
• family members,
• support workers,
• and the broader community.

It would also increase long-term system costs through crisis responses, emergency presentations, and higher-intensity interventions.

The Destructive 50% Reduction to Core Flexible Funding, which will likely include 24/7, 1:1 Support: The proposed reduction to social and community participation funding poses serious risks to participants requiring highly individualised support.

This participant currently relies heavily on flexible core funding across areas

including:

• daily living assistance,
• personal care and supervision,
• community participation,
• emotional regulation support,
• transport,
• and short-term respite.

From my direct experience supporting him, reducing these supports or replacing them with shared support arrangements would be unsafe.

He relies on consistency, predictability, and trusted relationships.

Forced 1:2 supports, group programs, or unsuitable shared environments are likely to increase distress, dysregulation, and behavioural incidents.

The current funding structure allows carefully tailored support arrangements that minimise risk and maximise stability.

The proposed changes threaten:

• community participation,
• mental health stability,
• respite for carers,
• independent skill-building,
• and long-term sustainability of family care.

Without appropriate supports, the burden shifts directly back onto unpaid family carers already operating under significant physical, emotional, and financial strain.

Redefining Parental Responsibility: The proposed expansion of “informal care” extectations is deeply concerning.

In practice, these reforms appear to assume that families can absorb increasingly complex disability care responsibilities indefinitely, regardless of age, capacity, eployment impacts, or burnout.

From my experience supporting this family unit:

• the participant requires substantial supervision,
• emotional regulation support is constant,
• behavioural management requires specialist understanding,
• and the care load already significantly limits workforce participation for family members.

These reforms risk normalising unsustainable levels of unpaid labour while removing formal supports that currently prevent collapse.

Families cannot replace specialist disability systems indefinitely.

The likely outcomes include:

• severe carer burnout,
• financial hardship,
• family breakdown,
• mental health deterioration,
• and increased reliance on emergency or hospital systems.

The Support Worker Registration: The proposed expansion of mandatory registration requirements for support workers may unintentionally force experienced independent workers out of the disability sector.

Several of the participant’s long-term support workers have worked with him for many years and understand his communication style, sensory profile, behavioural triggers, and support requirements.

These trusted relationships are critical.

Many independent workers may be unable or unwilling to manage the financial, administrative, and compliance burden associated with mandatory registration processes.

If these workers leave the sector, participants like him may be forced into unsuitable agency models with unfamiliar rotating staff.

For individuals with high anxiety and autism-related support needs, constant changes in workers can cause major distress and destabilisation.

• The reforms also threaten self-managed participants by undermining their ability to

• directly employ trusted workers outside large provider systems.

Removal of Diagnosis Lists and Transition to Standardised Assessments: The

move away from diagnosis-informed access toward standardised assessment

systems is one of the most concerning aspects of the reforms.

Complex neurodevelopmental disabilities cannot always be accurately measured

through rigid functional testing. PDA profiles in particular can present inconsistently depending on environment, trust, pressure, sensory load, and perceived demands. A participant may appear functional during assessment while still requiring extremely high support needs in real-world settings. Replacing multidisciplinary evidence and long-term practitioner understanding with standardised benchmarks risks excluding highly vulnerable participants whose disabilities do not present neatly within assessment frameworks. Federal Takeover of Support Coordination: The proposed move toward block-funded and government-commissioned support coordination services risks removing participant choice and continuity of care. For participants with severe anxiety, autism, and complex behavioural needs, trust and consistency are essential. Being assigned unfamiliar coordinators through centralised systems creates significant risks:

• breakdown of trust,
• disengagement from supports,
• increased distress,
• administrative failures,
• and reduced quality of care. The current ability to work with coordinators and support networks who genuinely understand the participant’s needs is vital to maintaining stability.

Expansion of Ministerial Rules and Legislative Instruments

The proposed expansion of Ministerial powers through legislative instruments raises significant concerns regarding transparency, procedural fairness, and participant security.

Participants and families should not be forced to live in uncertainty about whether essential supports may suddenly become restricted or removed through future rule changes without adequate consultation or parliamentary scrutiny.

The NDIS was originally designed around individualised support and participant choice.

These reforms risk shifting the scheme toward a rigid, centralised, top-down system focused primarily on expenditure reduction rather than human outcomes.

Conclusion

From my direct experience supporting a participant with severe and complex disabilities, I believe these reforms will not create sustainability.

Instead, they risk: - destabilising vulnerable participants, - collapsing informal family support systems, - increasing institutional reliance, - worsening mental health outcomes, - and shifting costs into emergency, hospital, and state-based systems.

The current NDIS framework, while imperfect, allows highly vulnerable individuals to maintain dignity, safety, community participation, and quality of life.

I strongly urge the Committee to reconsider these reforms and ensure that future changes are informed by meaningful consultation with participants, carers, frontline workers, disability advocates, and families directly impacted by these decisions.

I urge the Committee to make the following recommendations to Parliament:

              I respectfully urge the Committee to recommend that Parliament:

- Withdraw this Bill.

- Prioritise addressing fraud and systemic misuse rather than reducing
    
    participant eligibility and supports.

- Extend the Senate Committee consultation process.

- Conduct a comprehensive Human Rights Impact Review.

- Release all modelling regarding participant access, funding impacts, workforce
   
   impacts, and system changes.

- Restrict Ministerial determination powers.

- Preserve social and community participation funding.

- Retain individualised assessment approaches rather than automated
   
   decision-making systems.

- Preserve existing plan durations and reassessment protections.

- Avoid introducing harsh suspension or revocation provisions.

- Delay major access reforms until replacement systems are fully operational
  
  and independently evaluated.

- Release modelling regarding cost-shifting impacts to States and Territories.

- Protect self-management and participant choice in worker arrangements.

- Preserve participant choice and control.

- Ensure future reforms involve independent disability advocacy groups, carers,
  
  and lived-experience representatives.

Respectfully submitted by,

Breanna Bennett