From:

Clinical Supervisor, Behaviour Support,

Behaviour Support Practitioner (Proficient)

Email:

Date: 29 May 2026

Dear Committee Members,

I am writing to submit on the proposed National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

I acknowledge the Bill’s intent to ensure the sustainability, integrity, and long-term viability of the National Disability Insurance Scheme (NDIS). However, I hold significant concern that several proposed reforms may have unintended consequences for participants with complex disability, their unpaid carers, and the allied health workforce responsible for delivering and maintaining supports under the scheme.

Impact on participants with complex and fluctuating disability needs

The proposed tightening of eligibility criteria, including stricter evidence requirements regarding permanency and exhaustion of mainstream services, risks disproportionately impacting individuals with:

Autism spectrum disorder
ADHD with severe functional impairment
intellectual disability
trauma-related disability impacts
co-occurring psychosocial and neurodevelopmental conditions

These populations often present with fluctuating levels of functional capacity, where disability is not easily captured by static or time-limited assessments.

There is concern that stricter evidentiary thresholds may unintentionally:

Delaying early intervention supports
Increase diagnostic burden on families
Exclude individuals whose disability is episodic or context-dependent but still functionally significant
Shift costs to families and informal carers

Increased burden on parents

Parents Are Likely To Experience Increased Pressure As A Result Of:

more frequent reassessments and documentation requirements
higher evidentiary thresholds for continued support
increased administrative complexity in maintaining plans
delays in accessing or adjusting supports during periods of crisis or functional decline

For parents already managing high-support-needs individuals, including children with significant behavioural and sensory regulation needs, these changes will:

increase stress and burnout
reduce workforce participation
increase reliance on crisis services or out-of-home supports

As a parent of a child on the NDIS, policy changes that increase my burden risk destabilising my family’s well-being and system sustainability, as well as impacting the work that I do as a professional helping other families.

Implications For Allied Health Professionals

Allied health practitioners, including occupational therapists, psychologists, speech pathologists, and behaviour support practitioners, are likely to be significantly affected by: Increased Administrative Burden

More detailed and frequent reporting requirements
Expanded documentation to justify eligibility and funding continuity
Increased time spent on compliance rather than direct therapy

Impact On Service Delivery

Reduced clinical time available for participants
Longer waitlists due to administrative load
Increased pressure to provide evidence aligned with funding thresholds rather than clinical need

Ethical And Practice Tensions

There is a risk that practitioners may be placed in a position where:

Clinical judgement is constrained by funding eligibility frameworks
Functional need is underrepresented in formal documentation
preventative or early intervention work is deprioritised

Concerns Regarding Automated Decision-Making And Funding Controls

The proposed expansion of automated decision-making processes and Ministerial powers to define or limit “reasonable and necessary” supports raises concerns about:

- Transparency of decision-making criteria
- Consistency in outcomes across participants
- Reduced capacity for individualised assessment
- Limited recourse for complex or nuanced cases

Disability support requires a high degree of individualisation. Mechanisms that reduce human oversight may risk overlooking contextual factors critical to safe and effective support planning. As a professional working with participants for over a decade, since the very rollout of the scheme, not once have I ever seen two individuals with the same diagnosis present the same way or have the same needs.

Plan reassessment and variation restrictions

Stricter criteria for unscheduled plan variations and reassessments may unintentionally:

- Delay urgent adjustments during behavioural escalation, health deterioration, or environmental change
- Increase reliance on crisis pathways rather than preventative supports
- Reduce system responsiveness for participants with fluctuating needs

This is particularly relevant for participants with neurodevelopmental disabilities, where needs can change rapidly due to developmental stages, environmental stressors, or trauma triggers.

Recommendations for consideration

I respectfully recommend that the Committee consider:

 1. Ensuring eligibility criteria adequately recognise functional impairment, not solely diagnostic permanence
 2. Safeguards for participants with complex, co-occurring, or fluctuating disabilities
 3. Maintaining timely and accessible plan variation pathways in crisis or change contexts
 4. Protecting an adequate scope for clinical judgement by allied health professionals
 5. Ensuring transparency and appeal rights in any automated or algorithmic decision-making systems
 6. Recognising and supporting the essential role of unpaid carers, including minimising administrative burden
 7. Prioritising early intervention to reduce long-term system costs and crisis service reliance

Closing statement

While I support the intent of ensuring the sustainability of the NDIS for future generations, I am concerned that cost-containment measures must not come at the expense of access, equity, and functional support for those with the most complex needs.

The Bill will cause harm to participants, to families and carers, and to the workforce. In the medium to long term, it will harm the financial sustainability of the scheme it claims to protect, by pushing participants into more expensive forms of care while reducing the supports that keep them out of those settings.

A sustainable NDIS must be one that remains responsive to individual need, supports families and carers, and enables allied health professionals to deliver evidence-based care without disproportionate administrative burden.

Thank you for the opportunity to contribute to this important inquiry.

Sincerely,