Executive Summary

This submission outlines significant risks associated with proposed changes to the National Disability Insurance Scheme (NDIS), including public commentary regarding potential participant removal. Drawing on lived experience as a carer for multiple NDS participants, this submission identifies systemic failures in safeguarding, allied health regulation, market oversight, reassessment practices, and access barriers affecting children in specialist education settings.

The issues described demonstrate that tightening eligibility or removing participants cannot be responsibly considered without first addressing critical weaknesses in provider accountability, regulatory enforcement, and the broader disability support ecosystem.

Background and Context

Recent public statements by Minister Butler regarding NDIS reform have caused substantial distress for families supporting individuals with complex disability needs. For my family, removal from the NDIS would have severe and immediate consequences, including heightened exposure to homelessness, exploitation, and harm.

This submission provides evidence of systemic issues that must be considered in any redesign of the NDIS.

Risks to Participants with Complex Psychosocial and Cognitive Needs

My brother has a long history of extreme vulnerability prior to receiving NDIS supports. He experienced repeated episodes of homelessness and exploitation, including cuckooing — a practice in which individuals take advantage of a person’s mental illness or vulnerability to gain access to their home, remain there unlawfully, and use the space for their own purposes while intimidating or controlling the tenant.

Further information on cuckooing:

• LLR SAB Multi-Agency Guidance: Guidance for Working with Adults at Risk of Exploitation – Cuckooing https://www.llradultsafeguarding.co.uk/wp-content/uploads/2023/03/3.6-Cuckooing-Guidance.pdf (llradultsafeguarding.co.uk in Bing)

• Oxford City Council: Cuckooing https://www.oxford.gov.uk/info/20131/anti-social_behaviour/1295/cuckooing (oxford.gov.uk in Bing)

Without NDIS-funded supports, my brother would again be exposed to these dangers. The NDIS is the only mechanism currently keeping him safe, housed, and supported.

Failures in Allied Health Service Delivery and Workforce Oversight

Despite substantial funding in my brother’s plan, allied health service delivery has been

inconsistent, unsafe, and poorly regulated. Key issues include:

• inadequate oversight of allied health providers
• failure to deliver evidence-based interventions
• lack of accountability for poor practice
• withdrawal of services when concerns are raised

I am also concerned about broader market practices involving overseas-trained allied health workers, including underpayment, visa misuse, and unsafe working conditions. These practices place both participants and workers at risk and highlight gaps in regulatory oversight within the NDIS provider workforce.

These systemic failures must be addressed before any tightening of eligibility or removal of participants is considered.

Ineffective Safeguards and Provider Withdrawal

Multiple reports have been made to the NDIS Quality and Safegards Commission regarding serious concerns. However, meaningful outcomes or effective enforcement have not been observed.

In one case, both of my children were removed from a provider’s services after I queried billing practices. The justification provided was that they were “too complex.” This demonstrates a pattern in which providers withdraw services in response to scrutiny rather than assessed need.

Safeguarding mechanisms are not functioning as intended, and participants remain exposed to risk even when funding is present.

Psychological Harm Caused by Repeated Reassessment

The NDIS model of repeated reassessment and plan review causes significant psychological harm to families. Reassessment requires carers to repeatedly articulate the most difficult realities of their loved ones’ lives, often retraumatising them.

Key impacts include:

• ongoing emotional distress
• repeated revisiting of permanent diagnoses
• inability for families to stabilise or move forward
• retraumatisation associated with initial diagnostic confirmation

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The current system does not adequately recognise or mitigate this harm. Stability and continuity are essential for participants with lifelong or degenerative disabilities.

Barriers to Access for Children in Specialist School Settings

Multiple families in our school community have children who clearly meet the Victorian Department of Education’s eligibility criteria for enrolment in a specialist setting, yet remain unable to access the NDIS due to the financial barrier created by mandatory functional assessments.

These children already hold cognitive and educational assessments confirming intellectual disability. Despite this, the NDIS requires an additional, high-cost functional assessment costing several thousand dollars.

This creates a two-tiered system:

• children recognised by the Education Department as having significant disability
• the same children excluded from the NDIS because families cannot afford duplicate assessments

This disproportionately affects low-income and vulnerable families.

Misinterpretation of School Information Leading to Plan Reductions

NDIS planners have repeatedly reduced essential supports because our school’s website stated that the school “provides OT and Speech.” This wording referred only to universal, whole-school programs — not individual therapy or specialised intervention.

Despite clarification, reductions continued, and the school was forced to remove the wording to prevent further harm to families.

This demonstrates systemic misunderstanding of educational settings and inappropriate reliance on generic website content during planning.

Harmful Political Narratives and Public Commentary

Recent public commentary — including statements from senior government figures — has framed people with disability as a financial burden on the national budget. This narrative:

• stigmatizes individuals
• pits working-class families against one another
• fosters suspicion toward participants and providers
• undermines trust in the NDIS

Historical examples demonstrate the danger of portraying disabled people as a cost.

A well-known example is the propaganda used in Nazi Germany to justify the T4 Program, which dehumanised disabled people by portraying them as “too expensive” for society.

Summary of the T4 Program:

https://www.warhistoryonline.com/war-articles/action-t4- nazis-euthanasia-programme.html (warhistoryonline.com in Bing)

While Australia is a democratic nation with strong human rights protections, the lesson remains clear: narratives that reduce disabled people to budgetary liabilities are dangerous and must be challenged.

9. Summary of Systemic Issues Identified

Across my family and school community, the following systemic issues are evident:

- Families meeting educational disability criteria are blocked from NDIS access

due to financial barriers.

- Families within the scheme face reductions based on misinterpretation of

school information.

- Allied health market failures and unsafe workforce practices undermine

participant safety.

- Repeated reassessment causes significant psychological harm.

- Safeguarding mechanisms are ineffective.

- Public commentary has created a climate of suspicion that undermines

equitable access.

These issues must be addressed before any policy changes involving participant removal or eligibility tightening are implemented.

Conclusion

The concerns outlined in this submission demonstrate that proposed NDIS changes cannot be considered in isolation from safeguarding failures, market regulation gaps, and the lived experience of families supporting individuals with complex needs.

I urge the Senate to ensure that any future reforms prioritise safety, stability, and equitable access for all participants — particularly those who are most vulnerable.